Post on 26-Jul-2020
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Neart na Gaoithe and Inch Cape Offshore Wind Farm
Transponder Mandatory Zone (TMZ)
Stakeholder Consultation
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Executive Summary
Neart na Gaoithe Offshore Wind Limited (NNGOWL) and Inch Cape Offshore Limited (ICOL)
wish to respectively develop the Neart na Gaoithe and Inch Cape Wind Farms, referred to as
Neart na Gaoithe (NNG) and Inch Cape (IC). The Development Areas lie off the east coast of
Scotland with NNG lying to the south of IC by approximately 8 kilometres (km). NNG will be
located in the Outer Firth of Forth; 15.5 km from Fife Ness, with IC located approximately 15 km
off the Angus coastline.
What is the issue?
Leuchars is located on the east coast of Scotland approximately 11 km southeast of the City of
Dundee. The military base is the home of the Royal Scots Dragoon Guards; the Royal Air Force
(RAF) continues its presence and the airfield is currently home to the East of Scotland
University Air Squadron and No 12 Air Experience Flight whom provide training and air
experience flights utilising the Grob Tutor aircraft.
The presence of offshore Wind Turbine Generators (WTGs) at NNG and IC would be detectable
to the Leuchars Primary Surveillance Radar (PSR) and would have the potential to cause false
radar returns to be displayed to an Air Traffic Controller. This radar “clutter” could obscure
primary returns from actual aircraft and could interfere with radar tracking. This has the
potential to affect an air traffic controller’s ability to identify primary radar aircraft returns ,
diminishing the ability of the controller to provide the requisite Air Traffic Service (ATS), and
increasing the risk of the controller not detecting a conflict between aircraft. This requires a
change to the arrangements and procedures employed by ATS providers in the immediate
airspace surrounding the Development Areas. Large numbers of WTGs can also potentially lead
to saturation of the radar processing systems. For these reasons, a mitigation solution was
included as a requirement of the consents granted by the Scottish Ministers.
Until a technical PSR mitigation solution becomes available, it is proposed to introduce airspace
control measures through an Airspace Change Proposal (ACP) to remove and mitigate the
clutter presented by the WTGs on the Leuchars PSR radar display screen. The ACP describes the
method and responsibilities established to ensure that proposed changes to the dimensions,
classification or use of UK airspace are initiated, considered, refined, approved and
implemented, in a safe and controlled manner. It applies to all proposals for changes to the
status of UK airspace. NNGOWL and ICOL, the sponsors of the airspace change, are working
with the Ministry of Defence (MOD) and Leuchars to identify mitigation solutions to address the
impact of the WTGs on the Leuchars PSR, which will enable the NNG and IC WTGs to be
constructed and operated without affecting Leuchars flying and ATS operations. NNGOWL and
ICOL have engaged Osprey Consulting Services Ltd (Osprey CSL) to project manage the ACP on
their behalf.
Proposed solution
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In developing the plans to resolve the issues detailed in Section 3, NNGOWL and ICOL have
considered a variety of options to determine how best to meet the needs of the MOD as well as
other aviation stakeholders. Range Azimuth Gating (RAG), commonly referred to as radar
blanking, can be fitted to radar systems when local clutter conditions are considered
detrimental to Air Traffic operations. RAG has the effect of desensitising the radar system by
blanking out a portion of radar coverage over a specific area, RAG will need to be deployed over
the Development Areas before the WTGs become operational; in order to prevent the display of
WTG generated clutter on the ATC display at Leuchars. However, radar blanking will also
remove primary radar returns from aircraft within the blanked area; hence, in isolation it would
not provide sufficient mitigation. To mitigate this removal of primary radar data, it is necessary
to establish a Transponder Mandatory Zone (TMZ1) over the Development Areas so that aircraft
within the area will be visible to Air Traffic Control (ATC) utilising Secondary Surveillance
Radar (SSR).
There are two design options for the implementation of the TMZ and these are included and
illustrated within Section 1.3. The TMZs will have a lateral boundary that extends two Nautical
Miles (NM) around the edge of the Development Areas for both NNG and IC to allow for any
shadow effect and ‘building’ of primary radar tracks. The proposed ceiling of the TMZ is Flight
Level (FL) 100 within the operating hours of Leuchars ATS provision, which are 24 hours to
provide for military diversion aerodrome purposes and the provision of Lower Airspace Radar
Service (LARS2). Once consultation is complete, the application to the CAA for a TMZ will be
based on one of the two options. The TMZ will remain (subject to Civil Aviation Authority (CAA)
approval) in respect of the proposed developments until such time as a permanent technical
PSR mitigation solution can be identified and deployed in relation to the Leuchars PSR.
The establishment of the TMZ is one element of a two-part Mitigation Package aimed at negating
the impact of the clutter from the NNG and IC WTGs upon the Leuchars PSR. The two parts are:
Element 1: Establishment of a TMZ.
Element 2: RAG blanking (suppression of PSR returns within the RAG).
This document outlines the proposal from NNGOWL and ICOL to maintain the safety of the
airspace surrounding the Development Areas by mitigating the effects of the WTGs on Leuchars
ATS flying and radar based ATS operations.
Safety Case
Both MOD Number 1 Group (1Gp) and the CAA Safety and Airspace Regulation Group (SARG)
require assurance that the changes introduced by the Airspace Change will result in safe air
operations at all stages of the project lifecycle.
1 A TMZ is defined by the CAA as “a volume of airspace where aircraft wishing to enter or fly within the defined area will be required to have and operate secondary surveillance radar equipment”. TMZs are notified for the purposes of Article 39(2) of the Air Navigation Order 2010. 2 24 Hours, 7 Days a week (H24). The service is available to all aircraft flying outside Controlled Airspace up to and including FL 100, within the limits of radar / radio cover.
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CAA Civil Aeronautical Publication (CAP) 725 Guidance on the Application of the Airspace Change
Process [Reference 1] provides detailed guidance on the ACP. It requires a robust Safety
Management (SM) process to be an integral part of any proposed airspace change; Battlespace
Management Safety Management Manual (BM SMM) [Reference 2] provides the MOD direction
for the required safety assurance.
Stakeholder Consultation
NNGOWL and ICOL wish to engage with all parties that might be affected by this proposed
airspace change. All constructive feedback received will inform the development of its proposal,
ensuring that any positive impact is enhanced and negative impacts minimised.
This consultation is being undertaken in accordance with CAP 725 [Reference 1]. This
consultation document will aim to provide all of the information required for stakeholders to
make an informed decision on the impact of the proposed changes.
The consultation runs from 15 June 2015 to 7 September 2015, a period of 12 weeks.
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Contents
Acronyms 9
Defined Terms 14
1 Introduction...................................................................................................................................... 14
1.1 General ................................................................................................................................................. 14
1.2 Purpose and Objectives................................................................................................................... 16
1.3 Options for Application of the TMZ............................................................................................. 17
1.4 Document Structure......................................................................................................................... 19
2 The Consultation Process ........................................................................................................... 21
2.1 Overview.............................................................................................................................................. 21
2.2 What is This Consultation About? ............................................................................................... 21
2.3 Who are the Consultees .................................................................................................................. 22
2.4 Consultation Response.................................................................................................................... 22
2.5 Method of Consultation................................................................................................................... 22
2.6 Consultation CAA Oversight .......................................................................................................... 24
2.7 Confidentiality ................................................................................................................................... 24
3 The Need for an Airspace Change Proposal ....................................................................... 25
3.1 Overview.............................................................................................................................................. 25
3.2 Background......................................................................................................................................... 27
3.3 Data Capture....................................................................................................................................... 31
3.4 Justification for an ACP ................................................................................................................... 31
4 Proposed Design Option ............................................................................................................. 33
4.1 Overview.............................................................................................................................................. 33
4.2 Option 0 – Do Nothing ..................................................................................................................... 33
4.3 Option 1 – Temporary WTG Suspension of Operations ....................................................... 34
4.4 Option 2 – SSR Alone Operations................................................................................................. 35
4.5 Option 3 - Radio Mandatory Zone (RMZ) .................................................................................. 36
4.6 Option 4 - Transponder Mandatory Zone (TMZ).................................................................... 37
4.7 Conclusion ........................................................................................................................................... 38
5 Development of the Proposed TMZ........................................................................................ 39
5.1 Overview.............................................................................................................................................. 39
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5.2 Aim ........................................................................................................................................................ 40
5.3 TMZ Boundary Requirements and Operation ......................................................................... 40
5.4 Impact of the TMZ on Military Operations ............................................................................... 42
5.5 Impact of the TMZ on Other ATSUs............................................................................................. 42
5.6 Impact of the TMZ on Light GA Operations .............................................................................. 45
5.7 Impact of the TMZ on Offshore Helicopter Operations......................................................... 46
5.8 Helicopter Main Routes (HMR) .................................................................................................... 47
6 Environmental and Economic Considerations of a TMZ............................................... 48
6.1 Overview.............................................................................................................................................. 48
6.2 Impact of Noise .................................................................................................................................. 48
6.3 Anticipated Level of Fuel Burn/CO2 Emissions ....................................................................... 49
6.4 Anticipated Effect on Local Air Quality ...................................................................................... 49
6.5 Conclusions ......................................................................................................................................... 49
7 Next Stages ........................................................................................................................................ 50
7.1 Overview.............................................................................................................................................. 50
7.2 Consultation Summary.................................................................................................................... 50
7.3 Consultation Results ........................................................................................................................ 50
7.4 What Happens Next?........................................................................................................................ 51
8 References ......................................................................................................................................... 53
A1 Annex 1 NNG Wind Farm Line of Sight Assessment ........................................................ 55
A1.1 Overview .............................................................................................................................................. 55
A1.2 LOS Assessment Methodology ...................................................................................................... 56
A1.3 LOS Assessment Results .................................................................................................................. 56
A1.4 Conclusion ........................................................................................................................................... 57
A2 Annex 2 IC Wind Farm Line of Sight Assessment ............................................................. 58
A2.1 Overview .............................................................................................................................................. 58
A2.1 LOS Assessment Results.................................................................................................................. 59
A2.2 Conclusion ........................................................................................................................................... 60
A3 Annex 3 Cross Section of Airspace above the Development Areas .......................... 61
A4 Annex 4 Leuchars Instrument Flight Procedures............................................................ 62
A4.1 Overview .............................................................................................................................................. 62
A4.2 Leuchars Standard Instrument Departures (SID) – Runway 08 ........................................ 62
A4.3 Leuchars SID - Runway 26.............................................................................................................. 63
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A4.4 Leuchars HI TAC to Precision Approach (PAR) – Runway 08............................................. 64
A4.5 Leuchars HI TAC – Runway 08 ...................................................................................................... 64
A4.6 Leuchars TAC or RDR to ILS/DME - Runway 26 ..................................................................... 65
A4.7 Leuchars HI TAC - Runway 26....................................................................................................... 65
A5 Annex 5 Proposed TMZ Co-ordinates.................................................................................... 66
A6 Annex 6 Stakeholder / Consultee List ................................................................................... 70
A6.1 Aviation Consultees .......................................................................................................................... 70
A6.2 Non-Aviation Consultees ................................................................................................................ 73
A6.3 Information Organisations: Civil Aviation Authority............................................................. 73
Table of Figures
Figure 1 Location of the Development Areas in relation to Leuchars. .................................................. 14
Figure 2 Example of wind farm clutter from an offshore wind farm presented on to a radar
display screen.......................................................................................................................................................... 16
Figure 3 Design Option A of the TMZ application (the RAG will be located over the Developable
Areas). ........................................................................................................................................................................ 18
Figure 4 Design Option B of the TMZ application (the RAG is illustrated by the dark blue area
emcompassing the Developable Areas). ......................................................................................................... 19
Figure 5 Airspace in the vicinity of the Development Areas. ................................................................... 25
Figure 6 Leuchars ASA and the locations of the Development Areas. ................................................... 30
Figure 7 Option A: NNG and IC Proposed TMZ including 2 NM Buffer Zone (lined in green). ...... 41
Figure 8 Option B: NNG and IC Proposed combined TMZ including 2 NM Buffer Zone (lined in
green). ........................................................................................................................................................................ 41
Figure 9 NNG and IC Proposed TMZ (lined in green) ENR 6.1 proposed entry based on design
Option B..................................................................................................................................................................... 52
Figure 10 NNG Boundary Points around the Development Area considered for the LOS
Assessment............................................................................................................................................................... 55
Figure 11 LOS Profile between the Leuchars PSR and Point 1 at NNG . ................................................ 57
Figure 12 IC Boundary Points around the Development Area considered for the LOS
Assessment............................................................................................................................................................... 58
Figure 13 LOS Profile between the Leuchars PSR and Point A at IC. ..................................................... 60
Figure 14 Cross Section of Airspace above the Development Areas (not to scale) . .......................... 61
Figure 15 Leuchars SID Runway 08. ................................................................................................................ 62
Figure 16 Leuchars SID Runway 26. ................................................................................................................ 63
Figure 17 Leuchars HI TAC to PAR Runway 08. ........................................................................................... 64
Figure 18 Leuchars HI TAC Runway 08. ......................................................................................................... 64
Figure 19 Leuchars TAC or RDR to ILS/DME Runway 26. ........................................................................ 65
Figure 20 Leuchars HI TAC Runway 26. ......................................................................................................... 65
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Table of Tables
Table 1 Table of References................................................................................................................................ 53
Table 2 Summary of Development Area boundaries. ................................................................................. 55
Table 3 Summary of LOS results. ...................................................................................................................... 57
Table 4 Summary of Development Area Boundaries.................................................................................. 58
Table 5 Summary of LOS Results. ..................................................................................................................... 60
Table 6 Option A TMZ Co-ordinates. ................................................................................................................ 66
Table 7 Option B TMZ Co-ordinates. ................................................................................................................ 67
Table 8 TMZ Proximity to Military and Civilian Aerodromes. ................................................................. 69
Acronyms
Acronym Meaning
AAIB Air Accident Investigation Board
ACC Airport Consultative Committee
ACP Airspace Change Proposal
ACAS Airborne Collision Avoidance System
ADR Air Defence Radar
AEF Air Experience Flight
agl Above ground level
AIP Aeronautical Information Publication
amsl Above mean sea level
ANO Air Navigation Order
AOA Airport Operators Association
AOPA Aircraft Owners and Pilots Association
AR Airspace Regulation
ARA Advisory Radio Area
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ASA Advisory Service Area
ASL Above Sea Level
ATC Air Traffic Control
ATCO Air Traffic Control Officer
ATM Air Traffic Management
ATSOCAS Air Traffic Service Outside Controlled Airspace
ATS Air Traffic Service
ATSU Air Traffic Service Unit
BAA British Airports Association
BABO British Association of Balloon Operators
BALPA British Airline Pilots’ Association
BATA British Air Transport Association
BBAC British Balloon and Airship Club
BBGA British Business and General Aviation Association
BGA British Gliding Association
BHA British Helicopter Association
BHPA British Hand Gliding and Paragliding Association
BM Battlespace Management
BMAA British Microlight Aircraft Association
BMFA British Model Flying Association
BPA British Parachute Association
CAA Civil Aviation Authority
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CAP Civil Aviation Publication
CAS Controlled Airspace
CAT Commercial Air Transport
CO2 Carbon Dioxide
CTA Control Area (Class D UK Airspace)
CQWI Combined Qualified Weapon Instructors Course
DAATM Defence Airspace and Air Traffic Management
DAP Directorate of Airspace Policy (part of the CAA – now SARG)
DfT Department for Transport
DME Distance Measuring Equipment
DS Deconfliction Service
ELFAA European Low Fares Airline Association
ESUAS East of Scotland University Air Squadron
FL Flight Level
FOB Forward Operating Base
ft feet
GA General Aviation
GASCo General Aviation Safety Council
GAT General Air Traffic
GAPAN Guild of Air Pilots and Air Navigators
GATCO Guild of Air Traffic Control Officers
HCGB Helicopter Club of Great Britain
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HI TAC High TACAN
HMR Helicopter Main Routes
HQ DAAvn Headquarters Director Army Aviation
IAIP Integrated Aeronautical Information Package
IFP Instrument Flight Procedure
IFR Instrument Flight Rules
ILS Instrument Landing System
IMC Instrument Meteorological Conditions
IoMA Isle of Man Airport
km kilometre
LAA Light Aircraft Association
LARS Lower Airspace Radar Service
LJLA Liverpool John Lennon Airport
LoA Letter of Agreement
LOS Line of Sight
MAA Military Aviation Authority
Mil AIP Military Aeronautical Information Publication
MMATM Manual of Military Air Traffic Management
MOD Ministry of Defence
MTWA Maximum Total Weight Authorised
NAIZ Non-Automatic Initiation Zone
NATMAC National Air Traffic Management Advisory Committee
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NATO North Atlantic Treaty Organisation
NATS The National Air Traffic Service Provider
NERL NATS En-Route Ltd
NCHQ Navy Command Head Quarters
NM Nautical Miles
NO2 Nitrous Dioxide
NOTAM Notice to Airmen
OSA Off-Shore Safety Area
OS Ordnance Survey
PSR Primary Surveillance Radar
QRA Quick Reaction Alert
RA Regulatory Article
RAF Royal Air Force
RAG Range-Azimuth Gating
RDR Radar
RMZ Radio Mandatory Zone
SAR Search and Rescue
SARG CAA Safety and Airspace Regulation Group
SID Standard Instrument Departure
SM Safety Management
SMM Safety Management Manual
SRG Safety Regulation Group (part of the CAA)
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SSR Secondary Surveillance Radar
TACAN Tactical Air Navigation System
TMZ Transponder (SSR) Mandatory Zone
TRA Temporary Reserved Area
UAS University Air Squadron
UAV Unmanned Air Vehicles
UKAB UK Airprox Board
UKFSC UK Flight Safety Committee
VFR Visual Flight Rules
VGS Volunteer Gliding Squadron
VOR VHF Omni Directional Radio Range
Defined Terms
Acronym Meaning
Development Area The area of the Inch Cape or NNG Wind Farm which includes the WTGs,
inter-array cables, offshore substation platforms and initial part of the
Offshore Export Cable and any other associated works
Development Areas The combination of the Development Area as defined for both Inch Cape
and NNG
TMZ The Transponder Mandatory Zone, covering the Development Areas as
defined with a 5 NM separation distance between the Development
Areas, and a 2 NM buffer.
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1 Introduction
The presence of the Neart na Gaoithe (NNG) and Inch Cape (IC) Wind Farms will affect
Leuchars flying and Air Traffic Service (ATS) operations, with the most significant impact
being the detection of the Wind Turbine Generators (WTGs) as unwanted clutter by the
Leuchars Primary Surveillance Radar (PSR).
1.1 General
Neart na Gaoithe Offshore Wind Limited (NNGOWL) and Inch Cape Offshore Limited (ICOL)
wish to respectively develop the NNG and IC Wind Farms. The Development Areas are
illustrated in Figure 1 below and are adjacent to each other with NNG lying to the south of IC by
approximately 8 kilometres (km). NNG will be located in the Outer Firth of Forth,
approximately 15.5 km from Fife Ness, with IC located approximately 15 km off the Angus
coastline.
Figure 1 Location of the Development Areas in relation to Leuchars.
Contains Ordnance Survey data © Crown Copyright. All rights reserved. 2013.
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Leuchars is located on the east coast of Scotland approximately 11 km southeast of the City of
Dundee. The military base is the home of the Royal Scots Dragoon Guards; the Royal Air Force
(RAF) continues its presence and the airfield is currently home to the East of Scotland
University Air Squadron and No 12 Air Experience Flight whom provide training and air
experience flights utilising the Grob Tutor aircraft. However, the requirement for this airspace
change is not based on the routine activities of the Leuchars permanently based aircraft, which
are unlikely to operate near Development Areas, but on the ongoing and future military
operations conducted at Leuchars, which are detailed in Section 3.2.
The most significant impact from WTGs on the Leuchars PSR and its operational environment is
WTG generated radar returns causing false target generation. These false radar returns (also
known as “clutter”) displayed on the radar screen can be confusing to air traffic controllers;
false tracks (which in many cases are indiscernible from real tracks) could obscure returns from
real aircraft. This could affect an air traffic controller’s ability to identify primary radar aircraft
returns, undermining their ability to provide ATS and in turn increasing the risk of the
controller not detecting a conflict between aircraft. The presence of the NNG and IC WTGs will
affect Leuchars Aerodrome flying and radar based ATS operations thereby requiring a change to
the arrangements and procedures in the immediate airspace surrounding the Development
Areas.
Analysis completed as part of the Section 36 consent application for the NNG and IC Wind Farms
concluded that it is highly likely that the Leuchars PSR will detect all WTGs located within the
Development Areas. Annex A1 and Annex A2 provide example radar Line of Sight (LOS) profiles
for reference. This means that the WTGs are highly likely to generate returns similar to those
shown at Figure 2 below.
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Figure 2 Example of wind farm clutter from an offshore wind farm presented on to a radar display screen.
The green areas illustrate the moving blades of the WTGs.
A reduction in the detection capabilities of the radar and the generation of false targets from
WTGs will limit the ability of Leuchars ATC to discharge their responsibilities when providing
air traffic services within their area of operations. When providing a Deconfliction Service
(DS3), Leuchars ATC endeavours to provide five NM lateral separation between radar returns.
Therefore, services would be reduced, limited or downgraded within five NM of the boundary of
the clutter created by the WTGs.
1.2 Purpose and Objectives
An Airspace Change Proposal (ACP) to change the nature of the airspace within the area of the
WTGs is proposed in order to remove the clutter presented on the Leuchars PSR display screen.
The ACP describes the process and responsibilities established to ensure that proposed changes
to the dimensions, classification or use of UK airspace are initiated, considered, refined,
approved and implemented, in a safe and controlled manner. It applies to all proposals for
changes to the status of UK airspace. NNGOWL and ICOL, the sponsors of the airspace change,
are working with the MOD and Leuchars to identify mitigation solutions to address the impact
of the WTGs on the Leuchars PSR, which will enable the NNG and IC WTGs to be constructed and
operated without affecting Leuchars flying and ATS operations. Osprey CSL, on behalf of
3 Deconfliction Service provides the pilot with traffic information and deconfliction advice on conflicting aircraft. However, the avoidance of other aircraft is ultimately the pilot’s responsibility .
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NNGOWL and ICOL and in accordance with Civil Aviation Authority (CAA) Civil Aviation
Publication (CAP) 725, Guidance on the Application of the Airspace Change Process [Reference 1],
has prepared this consultation document. The purpose of this document is to provide
information regarding the proposal to establish a Transponder Mandatory Zone (TMZ) around
the Development Areas to mitigate the effects of the detection of unwanted WTG radar returns
by the Leuchars PSR. RAG has the effect of desensitising the radar system by blanking out a
portion of radar coverage over a specific area; this area of RAG blanking will be located over the
area of the development or developments specifically where WTGs are located. When the RAG
is selected, there would be no primary radar contacts within the area of the RAG; there would
therefore be a reliance on SSR data to provide surveillance radar cover for ATC purposes inside
the RAG inhibited area. A TMZ is required to mitigate the impact of Radar-Azimuth Gating
(RAG) of the Leuchars PSR.
1.3 Options for Application of the TMZ
A TMZ is airspace of defined dimensions wherein aircraft wishing to enter or fly within the
defined area, will be required to have and operate SSR equipment.
TMZs are notified for the purpose of Air Navigation Order (ANO) 2005 Article 20
[Reference 3] and a TMZ may be established for overriding safety reasons, where
the airspace classification would not ordinarily require aircraft to carry a
transponder; and
This SSR equipment must include a pressure altitude reporting transponder capable
of operating in Mode A and Mode C and have the capability and functionality
prescribed for Mode S Elementary Surveillance.
There are two design options for the implementation of the TMZ:
Option A: Individual TMZs with RAG blanking areas encompassing the separate NNG
and IC Development Areas.
Option B: A single TMZ with RAG blanking area encompassing both Development Areas.
Option A includes a lateral boundary that extends two NM around the edge of each of the
Development Areas for both NNG and IC, to allow for any shadow effect created by the WTGs
and ‘building’ of primary radar tracks.
Option B includes the same two NM lateral boundary extending around the single TMZ
encompassing both Development Areas. The proposed ceiling of the TMZ is Flight Level (FL)
100 within the operating hours of Leuchars ATS provision, which are 24 hours to provide for
military diversion aerodrome purposes and the provision the provision of Lower Airspace
Radar Service (LARS). The proposed options for the TMZ are illustrated in Figures 3 and 4
below.
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Figure 3 Design Option A of the TMZ application (the RAG will be located over the Developable Areas).
Reproduced from CAA digital map data © Crown copyright 2015. UK IAIP ENR.
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Figure 4 Design Option B of the TMZ application (the RAG is illustrated by the dark blue area emcompassing the
Developable Areas).
Reproduced from CAA digital map data © Crown copyright 2015. UK IAIP ENR.
Once consultation is complete, the application to the CAA for a TMZ will be based on one of the
two design options described above.
It is the responsibility of NNGOWL and ICOL as sponsors of the proposed change to consult with
all relevant stakeholders directly, or indirectly, affected by the proposal.
1.4 Document Structure
The objectives of the document are to:
Provide the background to the ACP;
Describe the ongoing and future operations at Leuchars and how these may be
affected by the NNG and IC WTGs;
Detail the proposed change to the airspace over the Development Areas; and
Describe the alternative options for mitigation which were considered and explain
why they are rejected due to their inability to mitigate sufficiently for the effects of
clutter created by the detection of WTGs.
This document contains eight main sections and six Annexes, outlined below for convenience:
Section 1, this section, introduces the document;
Section 2 outlines the consultation process;
Section 3 explains the necessity for an ACP;
Section 4 gives the proposed design option;
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Section 5 describes the development and options for the proposed TMZ;
Section 6 details the environmental and economic considerations;
Section 7 provides an outline of the next stages following consultation; and
Section 8 contains the table of References utilised throughout the document.
There are six Annexes:
Annex A1 details the radar LOS assessment for the NNG Wind Farm;
Annex A2 details the radar LOS assessment for the IC Wind Farm;
Annex A3 provides a cross section of airspace above the Development Areas;
Annex A4 illustrates the published Leuchars Instrument Flight Procedures (IFP);
Annex A5 provides the co-ordinates of the two design options for the proposed
TMZ; and
Annex A6 lists the Consultees.
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2 The Consultation Process
It is a CAA requirement that the Sponsor of an Airspace Change Proposal must conduct a
stakeholder consultation exercise prior to the submission of the Proposal.
2.1 Overview
The primary objective of the consultation process is to enable NNGOWL and ICOL to engage
with all parties that might be affected by the proposed airspace change, in order to ensure that
the development of the proposal is informed by constructive feedback. This section thus
provides an outline of the consultation process for NNGOWL and ICOL’s Airspace Change
Proposal. It includes details of why a consultation is undertaken, who has been sought to
engage in consultation and the method of consultation before explaining the CAA oversight of
the consultation process.
2.2 What is This Consultation About?
This consultation concerns the proposed implementation of a TMZ to mitigate the impact of NNG and IC WTGs on the Leuchars PSR. The TMZ is required to enable Leuchars to continue to provide safe and efficient ATS to aircraft once WTGs are operational. WTGs within the Development Areas are likely to cause false primary radar returns to be presented on Leuchars’ ATC radar display screens. These false tracks can obscure the primary returns generated by actual aircraft and impede an Air Traffic Control Officer’s (ATCO) ability to recognise genuine aircraft returns. Large numbers of WTGs can also saturate the radar processing systems leading to impaired radar performance. Before the WTGs become operational, the developers must agree an ATC mitigation scheme with the MOD. At this time, there is no proven technical solution or mitigation technology which can be used to upgrade the radar to remove the ‘clutter’; therefore, an operational solution is required. Aircraft transiting or operating within the proposed TMZ would be required to carry and
operate a working altitude reporting transponder. Within the Controlled Airspace (CAS) above
and adjacent to the proposed TMZ, there will be no changes to ATC procedures, the general
distribution of air traffic, or to the categorisation of the airspace.
It is a requirement of the CAA’s ACP (CAP 725) [Reference 1] that a sponsor undertakes a
stakeholder consultation process prior to the submission of an ACP. This ensures that all
stakeholders directly or indirectly affected by the proposed change are consulted, and are made
aware of any environmental and safety issues that may arise as a consequence of the proposed
airspace change. The CAA lays down its regulatory requirements and process for consultation
in CAP 725. The CAA Policy Statement for the Development of a TMZ [Reference 4] requires
that such airspace developments must be carried out in accordance with the ACP.
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NNGOWL and ICOL will collate and forward all consultation results to the CAA for their
consideration during the regulatory decision process.
2.3 Who are the Consultees
Consultees broadly fall into two categories:
Aviation consultees; and
Non-aviation consultees.
Aviation consultees include aviation parties such as the MOD, airlines, aircraft operators,
adjacent aerodromes, all local airspace users and the national bodies representing all UK
aviation interests who may be affected by the regulatory requirements within the TMZ.
Non-aviation stakeholders for consultation include but are not limited to environmental and
heritage organisations and the local lighthouse authority. The proposed TMZ would lie at a
distance greater than six NM offshore and consequently, in accordance with CAA guidance,
consultation with non-aviation stakeholders is limited. Fundamentally, the consultation will
enable NNGOWL and ICOL to obtain or confirm views and opinions about the impact of the
proposed airspace change. A full list of consultees, developed with the advice of the CAA, is
provided at Annex A6. Consultees have a crucial role in providing relevant and timely feedback
to NNGOWL and ICOL, giving their views and opinions on the impact of the proposed airspace
change. Consequently, it is vital that stakeholders fully participate in this consultation.
2.4 Consultation Response
Stakeholders are invited to comment on the proposals contained within the whole document
and the two design options for the TMZ. In reaching their conclusions, stakeholders are
requested to individually consider each of the two options for application of the TMZ. A
consultation response is requested if individually or any combination of the two options would
affect stakeholder operations. Stakeholders should consider the operating environment within
which the proposed TMZ lies and might like to consider the following questions before
responding:
Do you regularly fly in the airspace within the location of the Development Areas and
within the region of the proposed TMZ?
If yes, would the proposed TMZ affect your operation?
Are there any unforeseen consequences of the proposed TMZ, which the developers
should be made aware of?
2.5 Method of Consultation
The CAA requires that the consultation be conducted in accordance with the principles set out
in the Cabinet Office Code of Practice on Consultation, as specified in CAP 725 [Reference 1].
This consultation document is widely available and can be viewed on the NNGOWL and ICOL
websites at:
23
http://www.inchcapewind.com
http://www.neartnagaoithe.com
The developers request that you provide a written response; wherever possible, an early
response will allow the developers to address any questions or issues as soon as practicable.
The consultation period concludes at 1700hrs on 7th September 2015; responses received after
this date may not necessarily be considered.
Responses should indicate whether the respondent supports or objects to the proposal. In the
event that a respondent objects to the proposal, it is requested that supporting evidence is
included in the response. This consultation will be via email and postal responses. Please
respond even if you have no objection to the proposal.
Consultation responses may be sent by email to the following address:
NNI@ospreycsl.co.uk
Please compose your response in the following format:
Subject: NNG and IC Consultation Response
First Line of Text: “I am responding on behalf of [inset name of organisation]” or “I am
responding as a member of the public”.
Second Line of Text: Please select one of the following:
“I/We support all options of the NNG/IC TMZ proposal”;
“I/We object to all options of the NNG/IC TMZ proposal”; or
“I/We have no objection to all the options of the NNG/IC TMZ proposal“ .
Third Line of Text: (if required)
“I/We support only options A B (delete as required); or
“I/We object to options A B (delete as required).
Subsequent text:
Please include the reasons for supporting or objecting to the proposed NNG/IC TMZ;
alternatively, indicate your support or objection to one or more of the options for the TMZ
application.
Otherwise using the format above, correspondence may be sent by post to:
Osprey CSL
The Forge
Bentley
Hampshire GU10 5HY
24
Stakeholders should mark the letter “NNG and IC Consultation”.
2.6 Consultation CAA Oversight
Osprey, in compliance with CAP 725 [Reference 1], manages the consultation process on behalf
of NNGOWL and ICOL for the NNG and IC Airspace Change. Any complaints on the adherence of
Osprey, or NNGOWL and ICOL to the consultation should be addressed to CAA Airspace
Regulation (AR), using the contact details below:
Airspace Business Coordinator
Airspace, ATM and Aerodromes
CAA House
45-59 Kingsway
London WC2B 6TE
Email: airspace.policy@caa.co.uk
It should be noted that the CAA is responsible for overseeing the consultation process and will
therefore not comment on the proposed changes.
2.7 Confidentiality
The CAA requires that all consultation material, including copies of responses from consultees
and others, are included in any formal ACP submission to the CAA. Should stakeholders not
wish to pass personal details to the CAA, this should be indicated formally within the response.
However, the CAA is bound by the Data Protection Act and will protect all personal information
where provided. NNGOWL and ICOL undertake that, apart from the necessary submission of
material to the CAA and essential use by Osprey for analytical purposes, NNGOWL and ICOL will
not disclose personal details, or content of responses and submissions, to any third parties.
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3 The Need for an Airspace Change Proposal
Leuchars ATC operates under regulatory oversight of the Military Aviation Authority
(MAA), providing essential ATS to military and civil aircraft in the area the Development
Areas
3.1 Overview
The UK Government is legally committed to supporting renewable energy in order to meet its
target of generating 15% renewable energy by 20204. Furthermore, the Climate Change
(Scotland) Act 20095 contains provisions that set a legally binding target for reducing carbon
dioxide emissions by at least 42% by 2020 and at least 80% by 2050, compared to 1990 levels.
In order to increase and accelerate the generation of renewable energy in the UK, the UK and
Scottish Government’s policy, amongst other actions, sets out a plan for accelerating the use of
offshore wind. Figure 5 below shows the Development Areas in relation to the local airspace
environment.
Figure 5 Airspace in the vicinity of the Development Areas.
Reproduced from CAA digital map data © Crown copyright 2015. UK IAIP ENR
4 http://ec.europa.eu/energy/en/topics/renewable-energy 5 http://www.gov.scot/Topics/Environment/climatechange/scotlands-action/climatechangeact
26
The presence of operational WTGs within the Development Areas will affect the provision of
Leuchars ATS operations thereby necessitating a change to the arrangements and procedures in
the immediate airspace surrounding the Development Areas. In the event that the effects of
NNG and IC WTGs remain unmitigated, it is highly likely that the provision of radar based ATS at
Leuchars would be detrimentally affected. WTGs located within PSR coverage can reduce the
ability of the radar to detect aircraft. The WTGs present themselves as a large number of
reflecting moving targets to the radar, which look very similar to aircraft radar returns. Each of
these effects reduces the overall effectiveness of the radar in detecting targets, which can result
in misidentification of aircraft, loss of track position, loss of track identity and false plots; these
in turn can potentially cause safety and operational issues. To mitigate the effects of the WTGs
it is proposed to implement an ACP through the establishment of a TMZ to mitigate the impact
of radar blanking techniques on the Leuchars PSR.
Implementation of the TMZ will not occur until the first WTG becomes operational (radar
clutter is not apparent until the WTGs are rotating). A positive decision on the application for a
TMZ will form the basis for the discharge of certain conditions attached to Section 36 consents.
This section describes the relevant background information to this ACP by providing an
overview of flying operations at Leuchars. It also highlights the primary areas of concern
relating to the effects of NNG and IC WTGs on flying and radar based ATS operations at
Leuchars. In this case, there are five principal issues concerning the effects of the NNG and IC
WTGs on Leuchars operations.
Approach Control and Departure Services to Leuchars;
Radar based ATS provision within the vicinity of NNG and IC Wind Farms and the
established Leuchars IFPs located overhead the Development Areas;
Radar based ATS provision to military aircraft within the Leuchars Advisory Service
Area (ASA);
The capability to operate as a radar equipped Instrument Flight Rules (IFR)6
aerodrome; and
The requirement to host North Atlantic Treaty Organisation (NATO) and other
major exercises.
6 IFR – Instrument Flight Rules are a set of regulations that governs flights under conditions in which flight by outside visual reference is not safe. IFR flight depends upon flying by reference to instruments in the flight deck.
27
3.2 Background
Following the 2010 Strategic Defence and Security Review7, the MOD announced that the RAF
would transition to one main operating base in Scotland; RAF Lossiemouth in Morayshire was
identified as the selected base. Typhoon aircraft, formerly based and operating from RAF
Leuchars, have now relocated to their new base at RAF Lossiemouth. On the 1st April 2015,
Leuchars transitioned to British Army control. The East of Scotland University Air Squadron
(ESUAS) and No12 Air Experience Flight (AEF) still operate from the airfield sharing a fleet of
seven Grob Tutor aircraft, although two of these are based permanently at Glasgow
International Airport for University Air Squadron duties. Leuchars Flying Club also operates
three general aviation aircraft for hire and training. The requirement of the TMZ is not based on
the routine activities of the Leuchars permanently based aircraft, which are unlikely to operate
near the Development Areas, but on the ongoing and future military operations conducted at
Leuchars, detailed below:
The MOD Chief of the Air Staff has directed that Leuchars retain a 24/7 IFR radar
service capability in order to act as a Diversion Aerodrome for military aircraft,
primarily Typhoon aircraft based at RAF Lossiemouth, including those operating
Quick Reaction Alert (QRA)8 sorties from RAF Lossiemouth and RAF Coningsby, but
also for other aircraft completing training sorties/missions from other military
bases, to recover to the aerodrome safely in poor weather conditions;
Leuchars will host exercises and detachments, both UK Mil and major NATO
exercises (Joint Warrior); this capability will be maintained with Leuchars
operating as a Forward Operating Base (FOB) within the military exercise
scenarios;
Leuchars will also host the Combined Qualified Weapon Instructors Course (CQWI);
successful completion of this course leads to a formal qualification, which is
essential to enable aircrew to return to the frontline to instruct weapons and tactics
on operational squadrons. The Course is intensive, lasting five months, during
which increased flying activity culminates into an ‘operational phase’ of tactical
flying; and
The proximity of the aerodrome to the military practice Danger Areas to the east
and southeast makes Leuchars an attractive option for aircraft diverting in
following an emergency or due to inclement weather conditions at their home base.
Leuchars ATC provides aerodrome control and approach control services to a range of general
aviation and military aircraft in the airspace around Leuchars. In addition to these standard air
traffic tasks, Leuchars ATC provides a service to aircraft participating in the Lower Airspace
7 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/62482/strategic-defence-security-review.pdf. 8 Aircraft are kept at a permanent readiness state in order to react to situations of national security.
28
Radar Service (LARS9) within a radius of 40 NM of the airfield every day of the year, 24 hours
per day.
The Leuchars ASA is notified as an airspace of defined dimensions where military aircraft that
are carrying out autonomous operations within the area are to receive, where possible, an
ATSOCAS10 from a nominated source. Pilots are responsible for selecting the ATS provider and
the type of ATS required from the provider.
The obligation to provide standard radar based ATS, the requirement to host complex NATO
exercises, the LARS commitment, the requirement to provide radar services within the ASA for
military aircraft together with the requirement to standby as an emergency diversion
aerodrome in all weather conditions, all combine to create an extremely complex controlling
environment. The ability to mitigate the impact of the WTGs on the Leuchars PSR is paramount
to ensure that the required levels of safety exist in order to operate a mix of aircraft efficiently
and effectively in the local operating areas.
3.2.1 Leuchars ATS
The airspace around Leuchars is of medium complexity11. Leuchars ATC provides a radar based
ATS to aircraft outside of controlled airspace, (generally Class G uncontrolled airspace) that are
departing, arriving and transiting through the area (generally within 40 NM radius from
Leuchars Aerodrome) as well as those military aircraft, requesting an ATS and operating within
the Leuchars ASA.
3.2.2 Provision of an Approach Control and Departure Service
Leuchars ATC provides an approach control and departure service in accordance with the MAA
Manual of Military Air Traffic Management (MMATM) [Reference 5]. Leuchars ATC provides an
ATS to Grob Tutor aircraft following the recommendation from the Air Accident Investigation
Board (AAIB) accident report 6/2010 into the mid-air collision between two AEF Grob 115E
Tutor aircraft in 2009. Air Officer Commanding (AOC) No 22 Group (controlling authority for
Grob Tutor aircraft) has mandated that Tutor aircraft are to maintain a radar service during
flying operations. The five tutor aircraft presently permanently based at Leuchars are unlikely
to operate in the location of the Development Areas. Due to their single engine status, sorties
over the open sea area are likely to be restricted to a few miles offshore.
Leuchars publishes a number of precision approach, standard arrival and departure procedures
within the Military Aeronautical Information Publication (Mil AIP) [Reference 6]. A number of
these procedures are located within the vicinity of the Development Areas.
9 LARS - The service is normally provided to radius 30NM, Leuchars provide the service to 40 NM. 10 ATSOCAS – Air Traffic Service Outside Controlled Airspace. UK Flight Information Services provided by a number of air traffic units and is used by a variety of users. 11 Can be characterised by the operation of a few CAT movements per hour and a number of flights in the airspace operating under Visual Flight Rules (VFR); the most prevalent being survey and offshore resource recovery operations and the Military.
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3.2.3 Leuchars LARS
Leuchars ATC provides a LARS with the purpose of ensuring participating pilots are aware of
other nearby aircraft and/or flying activities thus enhancing flight safety in the area. This
service is available to any aircraft operating in uncontrolled airspace, from ground level up to
10,000 feet (ft), within a 40 NM radius of Leuchars and is provided in accordance with the
policy determined by the CAA Safety and Airspace Regulation Group (SARG). LARS is regarded
as a very important service which is sponsored by the Department for Transport (DfT) and is
determined by the CAA SARG as key to enhancing the levels of safety of the airspace in an area
that can be busy with a diverse mixture of aviation activities.
3.2.4 Leuchars ASA Activities
Leuchars ATC, together with other ATS providers, are responsible for providing radar services
in the Leuchars ASA to enhance the safety of aircraft operating in the area. The Leuchars ASA is
notified from 5,000 ft above mean sea level (amsl) to FL 195 (approximately 19,500 ft) where
pilots of military fixed wing, fast jet aircraft are advised, where possible, to take advantage of
receiving an ATS when flying within the area to enhance flight safety. Leuchars can only control
aircraft within the ASA up to FL 195; above this level, aircraft are under the control of military
controllers at an Area Control Centre (ACC) or Air Defence Controllers. The vertical limit of the
ASA can be increased to FL 245 (approximately 24,500 ft) when Temporary Reserved Area
(TRA) 007 / 007A is inactive, (Class C controlled airspace (CAS)). To avoid operational
restrictions, TRAs allow military aircraft to work autonomously under Visual Flight Rules 12
(VFR) or be in receipt of an ATS from approved ATS units. TRA 007/A is activated Monday
through to Friday between the hours of 0730-1700 during the summer and 0830-1700 during
the months of winter; it may be activated by Notice to Airmen (NOTAM) at other times.
The Development Areas are located within the lateral extent of the Leuchars ASA. Unmitigated
WTG radar returns on the Leuchars PSR will have an impact on the level of service provided to
aircraft within the area. There would be a detrimental effect on the provision of timely
information by the air traffic controller to assist the pilot in discharging his responsibility for
collision avoidance within five NM of the Development Areas. Figure 6 below illustrates the
Leuchars ASA and the approximate locations of the Development Areas.
12 VFR – Visual Flight Rules. A set of regulations under which a pilot operates an aircraft in weather conditions generally clear enough to allow the pilot to see where the aircraft is going. The pilot operates the aircraft with visual reference to the ground and by visually avoiding obstructions and other aircraft.
30
Figure 6 Leuchars ASA and the locations of the Development Areas.
© UK MOD Crown Copyright, 2014 Crown Copyright material reproduced with the permission of the Controller of HMSO.
3.2.5 Leuchars Instrument Flight Procedures (IFP)
Leuchars has published a number of IFPs for its predominant Runways designated as 08/26.
These consist of the following:
Standard Instrument Departure13 (SID) Runway 08;
SID Runway 26;
High TACAN14 (HI TAC) to Precision Approach Radar15 (PAR) Runway 08;
HI TAC Runway 08;
TAC or Radar (RDR) to Instrument Landing System; (ILS)/Distance Measuring
Equipment16 (DME) Runway 26; and
13 SID – Standard Instrument Departure. An ATC coded departure procedure established at airfields. SIDs strike a balance between terrain and obstacle clearance, noise abatement and airspace restrictions. 14 TACAN – Tactical Air Navigation System. A navigation system used by military aircraft; it provides the user with a bearing and a distance to a ground or ship based station. 15 PAR – Precision Approach Radar. A type of radar guidance system designed to provide lateral and vertical guidance to an aircraft pilot for landing, until the pilot touches down. 16 DME – Distance Measuring Equipment. A transponder based radio navigation system that measures slant range distance by timing the propagation delay of radio signals.
31
HI TAC Runway 26.
Charts depicting the IFPs for Leuchars including an overlay of the proposed location of the NNG
and IC development sites are illustrated in Annex A4.
3.3 Data Capture
Since Typhoon aircraft left Leuchars and during the months October 2014 to April 2015, the
airfield has carried out, on average, 936 aircraft movements per month, which includes the
normal activity of the based Tutor and Flying Club aircraft, rotary and other civil and military
aircraft. The airfield also saw a number of visiting aircraft consisting of the following:
Detachment of Alphajet, Hawk, King Air, Puma, Lynx and Tucano aircraft;
Executive Aircraft, C130 Hercules and Boeing 737;
During January to April 2015, 154 military aircraft consisting of Tornado GR4,
Sentinel, Shadow, Learjet, Typhoon, DA20 and Hawk aircraft completed Practice
Diversions17 to the Airfield; and
January to April 2015, Leuchars completed 148 instrument approaches consisting
of Radar Talkdowns18, Instrument Landing System19 and Other Aids20 approaches.
During the period October 2014 to March 2014, 20 aircraft of differing types diverted to the
airfield. Notably during December 2014, 7 RAF Lossiemouth based Typhoon aircraft diverted to
Leuchars after the runways at Lossiemouth became unusable. During February 2015, five Hawk
aircraft and two Tucano aircraft diverted to Leuchars with varying emergencies. A number of
non-SSR equipped general aviation aircraft were controlled up to the end of April 2015, none of
which operated within the vicinity of the proposed TMZ, all staying close to the coastline.
3.4 Justification for an ACP
The impact of the NNG and IC WTGs on Leuchars’ flying and ATS operations relate to the issues
detailed in Section 3.1 and 3.2. These areas of concern have led to the requirement to mitigate
the effects of the NNG and IC WTGs.
Leuchars ATC is responsible for providing pilots with ATS in Class G uncontrolled airspace
directly above the proposed developments; this includes those aircraft arriving/departing from
the aerodrome as well as those military and civil aircraft transiting the area. Leuchars plays a
key role in being a provider of LARS in the North East of Scotland as there is limited radar
coverage below FL 100 in the area. This service would necessarily be reduced, downgraded or
17 A practice diversion to an airfield is usually pre-booked. Aircraft will complete an approach to the runway for practice to simulate that the intended airfield of destination is unusable or that there is a simulated emergency with the aircraft. 18 A controller guides aircraft down to the runway threshold or to a point where the aircraft reaches a defined decision height/altitude. 19 ILS – a ground based instrument approach system that provides precision lateral and vertical guidance to the runway. 20 May include TACAN / Internal Aid approaches, which are interpreted by the pilot.
32
limited near the Development Areas if the radar returns from the WTGs (clutter) remain
unmitigated.
33
4 Proposed Design Option
The proposal is to establish a TMZ with associated RAG and a 2 NM buffer zone around the
Development Areas.
4.1 Overview
In developing the plans to resolve the issues detailed in Section 3, NNGOWL and ICOL have
considered a variety of design options in order to provide sufficient mitigation, whilst meeting
the needs of the MOD and all other aviation stakeholders.
The following range of mitigation design options were considered:
Do nothing;
The ability to temporarily close down the operation of the WTGs;
SSR Alone operations;
Radio Mandatory Zone (RMZ);
TMZ with associated RAG blanking and no lateral geographic buffer zone; and
TMZ with associated RAG blanking and lateral geographic buffer zone.
4.2 Option 0 – Do Nothing
In the event that no mitigating actions are implemented for the NNG and IC Wind Farms, the
clutter created by the WTGs will affect the safe and effective provision of a radar based ATS at
Leuchars in the ways described below.
WTGs located within PSR coverage can reduce the ability of the radar to detect aircraft. The
WTGs present themselves as a large number of reflecting moving targets to the radar (Figure 2),
which look very similar to aircraft radar returns. WTGs detected by radar create the following
effects:
False returns causing false target generation;
Loss of receiver sensitivity;
Plot extractor/filter memory overload;
Presenting an obstruction (shadow); and
Receiver saturation.
Each of these individual effects reduces the overall effectiveness of the radar in detecting
targets, which can result in the misidentification of aircraft, loss of track position, and loss of
track identity as aircraft symbols and track history may be obscured. These in turn can affect
the accuracy and timeliness of controller instructions and potentially cause serious safety and
operational issues to ATC and the flying community operating within the area of WTG induced
radar clutter.
34
The Chief of the Air Staff intends to maintain Leuchars as a radar equipped IFR Diversion
aerodrome, available 24 hours a day, seven days a week in order to provide a suitable diversion
aerodrome for QRA sorties from RAF Lossiemouth and RAF Coningsby, as well as other aircraft
completing sorties from other RAF or NATO bases.
If mitigation is not introduced, Leuchars controllers would be required to ‘reduce’ the ATC radar
services that it provides to aviation operating within the vicinity of the Development Areas to an
unacceptable level. Controllers would be required to vector aircraft around the clutter and this
would inevitably lead to greater track distances flown and an increase in both pilot and
controller workloads. Established IFPs detailed in 8A4, which are located close to the locations
of NNG and IC, for aircraft operating in and out of the aerodrome, are likely to require alteration
or may even be prohibited, if the clutter created by the WTGs remains unmitigated. This would
lead to greater noise exposure to communities, greater fuel burn and an increase in NO2 and CO2
emissions through extended routing around the WTG clutter.
4.3 Option 1 – Temporary WTG Suspension of Operations
Clutter on the Leuchars PSR would only be apparent once the WTGs become operational. The
technical and commercial complexities associated with this option are listed below:
Frequency and duration of switch offs. WTGs are turned off for maintenance
however, any increase in the activation and deactivation of the WTGs would lead to
excessive wear and tear;
As any instruction to turn off the WTGs is not likely to be immediate, there is
uncertainty over the time it would take for the WTGs to stop turning; and
The MOD would effectively require the rights to turn off the WTGs at any point in
time for any duration.
Consideration was given to providing the ability to close down the WTGs via a telephone call to
the NNG or IC operations rooms. However, due to the unpredictable nature of operations within
uncontrolled airspace, in which the WTGs are located, this option is unviable, as it would be
unable to be sufficiently robust for the dynamic ATC operational environment. Control of the
WTGs would remain with the respective developer, and the time taken in initiating the request
and the cessation of WTG operations would introduce delay and increased workload at a time
when speed is of the essence to ATC.
This option is also not practical from a technical point of view. Electrical generators have a
ramp down rate: this is the limit at which the machine can safely reduce its power output to
zero, without causing significant aging and/or damage to the equipment. The electrical
machines and mechanical equipment need to brake and reduce speed in a controlled manner
and emergency stop procedures should only be implemented in emergency conditions.
This option would not be acceptable to NNGOWL or ICOL; furthermore, in the fast moving,
dynamic world of ATC operations, Option 1 would be operationally unmanageable, and
35
unacceptable to the MOD. Consequently, Option 1 is rejected as it provides insufficient
mitigation for the effects on the Leuchars PSR.
4.4 Option 2 – SSR Alone Operations
SSR is a co-operative surveillance technique that relies on the aircraft being equipped with a
transponder. The target aircraft's transponder responds to interrogation by the ground station
by transmitting a coded reply signal.
It should be noted that the circumstances when SSR may be used alone in the provision of ATS
are limited. The International Civil Aviation Organization (ICAO) Procedures for Air Navigation
Services – Air Traffic Management (PANS-ATM) states at Section 8, paragraph 8.1.9:
8.1.9 SSR systems, especially those utilizing monopulse technique or having Mode S capability, may
be used alone, including in the provision of separation between aircraft, provided:
a) the carriage of SSR transponders is mandatory within the area; and
b) identification is established and maintained.
For the UK, the requirement is articulated within CAP 493 Manual of Air Traffic Services (MATS)
Part 1 [Reference 7], Chapter 3, as follows:
10B Use of SSR alone
10B1 Provided the pilots are made aware of the limitations of the service, SSR may be used to
provide horizontal separation in the following circumstances:
1. In accordance with MATS Part 2;
2. To overcome temporary deficiencies within PSR cover, such as fading or clutter,
the SSR return only of one aircraft may be used to provide separation from the PSR
or SSR return of another aircraft provided the PSR and SSR situation displays are
correctly aligned. In this context ‘unavailable for use due to maintenance’ does not
constitute a ‘temporary deficiency’; and
3. Immediately after PSR failure for the minimum time necessary to establish
procedural separation. Once established, services normally provided using radar
may be resumed when the PSR is serviceable.
10B.2 SSR shall not be used to provide horizontal separation if a controller has any doubt about
the accuracy of the position symbol due to equipment malfunction, reflections or any other reason.
The MOD and MAA provide Regulatory Articles (RA) to provide a framework of policy, rules,
directives, standards, processes and the associated direction, advice and guidance, which
governs military aviation activity and against which air safety is assessed. RA 3241 [Reference
8] covers contingency arrangements for the continued provision of ATS utilising SSR alone.
Implementation of Leuchars ATS incorporating the NNG/IC TMZ will be acceptably safe and will
36
continue to be so within context of current operations. Military ATC terminal21 radar
controllers may provide an ATS using SSR alone providing its use is defined in unit orders.
However, military controllers are encouraged (in accordance with local orders) to hand-over
control of aircraft to adjacent units within overlapping radar coverage (subject to the adjacent
unit’s radar serviceability) at the earliest opportunity, when other mitigation methods are not
available. This is impracticable within the vicinity of the Development Areas as there is limited
overlapping radar cover with adjacent LARS units, (the nearest being RAF Lossiemouth, 81 NM
to the north of Leuchars).
In areas of airspace that are not significant to the normal operations at an aerodrome,
controllers in some cases are able to tolerate clutter presented onto radar screens. Since it is
not possible to deselect PSR for specific areas and the airspace above the Development Areas is
of operational significance to Leuchars, by deselecting the PSR would mean that the entire area
of operations for the Leuchars controller would be without PSR data displayed. This means that
it will not only be impossible to detect any aircraft entering the airspace above the Development
Areas, but any aircraft operating within 40 NM of Leuchars without a transponder fitted and/or
without the transponder activated would be undetectable. This would lead to an unacceptable
loss of situational awareness for the controller and potentially an increased risk of mid-air
collision.
The option of utilising SSR alone operations without a TMZ has been rejected. Non-
transponding aircraft would remain undetectable within the Development Areas and potentially
the entire area of Leuchars operations if the primary radar was deselected, resulting in an
unacceptable loss of situational awareness.
4.5 Option 3 - Radio Mandatory Zone (RMZ)
An RMZ is an area of defined dimensions within which a pilot must be in two-way
communication with the airspace owner, prior to entry. Pilots must also provide information
pertinent to the flight, for example, route required and altitude/height. An RMZ created in the
airspace above the WTGs would provide a degree of situational awareness to the controller
about the nature of the aviation within the airspace.
Although ATC would be able to provide some level of service to aviation operating within the
Development Areas, it would not prevent the generation and display of false tracks with the
associated loss of situational awareness. An RMZ might also reduce the effectiveness of
Airborne Collision Avoidance Systems (ACAS) in the zone, since there is no requirement for
aircraft entering the area of clutter to be fitted with an SSR transponder. ACAS systems rely on
the cooperative nature of SSR transponders to resolve potential collisions vertically. This
operational mitigation does not go far enough to reduce the risk of collision, as it increases
controller situational awareness but does not allow controllers to determine the position of all
aircraftt; ATC would not see all aircraft within the clutter and would not be able to provide the
21 Terminal Radar refers to radars situated at airfields.
37
prescribed separation between aircraft. For these reasons, Option 3 is rejected as it provides
insufficient mitigation.
4.6 Option 4 - Transponder Mandatory Zone (TMZ)
4.6.1 Option 4a - TMZ with associated RAG (PSR blanking) and no lateral geographic
buffer zone
A TMZ without blanking of the Leuchars PSR with RAG was not considered a viable option for
mitigation. Without the use of RAG, primary radar clutter could negatively affect the degree,
accuracy and timeliness of the instructions, advice and information a controller is able to
provide to pilots within the TMZ, with consequent impacts on safety and expedition. There
could be an increase in controller workload and the clutter could also result in poor radar
performance as a result of processing saturation and desensitisation or shadowing, resulting in
loss of radar detection of aircraft within the vicinity of the TMZ. For these reasons, the TMZ
only option is rejected as providing insufficient mitigation.
Within this proposed solution, the establishment of the TMZ is one element of a two-part
Mitigation Package aimed at negating the impact of the clutter from the NNG and IC WTGs upon
the Leuchars PSR. The two parts are:
Element 1: Establishment of a TMZ; and
Element 2: RAG with associated suppression of PSR returns within the RAG.
A RAG involves blanking the clutter (WTGs) from showing on radar displays. It blanks all
returns in the area of the source of clutter (WTGs) itself and removes it from the controllers
display. This means that, within the area of the RAG, the radar will not detect any primary
contacts (from WTGs or aircraft) and therefore they will not appear on the controllers radar
display screen. However, since aircraft entering the TMZ area must be equipped with an
operational transponder, the controller will be able to track the aircraft using its SSR
transponder.
This proposed solution provides Leuchars ATC with the capability of assured positional
identification and provides Commercial Air Transport (CAT) operators with collision avoidance
mitigation through the cooperative use of ACAS. It will also maintain current levels of safety for
the provision of radar services provided using SSR data-only within the vicinity of the
Development Areas in accordance with ICAO PANS-ATM ‘the carriage of SSR transponders is
mandatory within the area’. Aircraft flying through the TMZ will be required to be equipped
with and operate SSR transponder equipment or to have established two-way radio
communications with Leuchars ATC, the TMZ Controlling Authority. As stated in Section 4.4,
military ATCOs may provide an ATS using SSR alone providing its use is defined in unit orders.
SSR alone service can be provided to aircraft participating in LARS where no overlapping radar
coverage is provided by adjacent LARS units, however once the aircraft is within overlapping
radar coverage of an adjacent LARS unit, the aircraft should be handed over [Reference 8].
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The airspace classification of a TMZ would remain unchanged. Hence, the ATS available within
and around the TMZ would continue to be applied according to CAP 774 The UK Flight
Information Services [Reference 9] through the assured provision of SSR data to the controller.
The TMZ proposed under Option 4a purely covers for the geographical layout of the
Development Areas and does not consider the establishment of a buffer zone. As outlined below
(section 4.6.2), this could have detrimental effects on ATS provision and its safety. Setting up a
TMZ without an additional buffer zone around the RAG would prevent the controller from
maintaining primary radar track identity as the aircraft enters / leaves the TMZ. Option 4a
(TMZ without a Buffer Zone) has therefore been rejected as it provides insufficient mitigation.
4.6.2 Option 4b - TMZ with associated RAG (PSR blanking) and lateral geographic
buffer zone
This option is identical to Option 4a above with the exception that in this case, the TMZ is
increased slightly to cater for the addition of a buffer zone around the Development Areas. This
allows the PSR to re-establish a target / plot once an aircraft has exited the RAG (blanked) area
(particularly to the west of the RAG as aircraft approach Leuchars).
The Leuchars Watchman radar displays unprocessed video and on turning the radar on (usually
the radar is operated H24, although in quiet periods during the evening, displays may be de-
selected) it takes a few sweeps for the returns on the display to stabilise; essentially all returns
are displayed in real time. The worst case would be a target appearing just after the antenna
has passed, this target would not be picked up until the antenna illuminated it on its next pass
which would be around 4 seconds (at 15 rpm), plus a small amount for the time it takes for the
signal to pass through the circuitry. The TMZ around the London Array Offshore Wind Farm,
administered by Southend ATC, has an internal buffer of two NM to cater for this type of
occurrence.
Until a permanent technical solution to the PSR is identified and implemented, the MOD has
agreed to support the establishment of a TMZ with Option 4b, to establish a TMZ with RAG and a
two NM buffer zone around the Development Areas. The lateral TMZ boundary would extend
two NM around the edge of the Development Areas to allow for any shadow affect and ‘building’
of processed radar track as aircraft leave or operate in the vicinity of the RAG. Section 5.3.1
below provides further details the TMZ horizontal buffer zone.
4.7 Conclusion
Each of the aforementioned options has been considered in depth. The mitigation option that
provides the best solution for the effects of WTG generated clutter on the Leuchars PSR display
is Option 4b, to establish a TMZ with an associated buffer, together with associated RAG,
(blanking of PSR returns within the RAG). This mitigation option will also satisfy the Section 36
consent conditions imposed by the Scottish Government to mitigate the effects created by the
development on the Leuchars PSR. The development of this mitigation option for the
configuration of a TMZ is provided in Section 5.
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5 Development of the Proposed TMZ
The overall aim of the NNG and IC Airspace Change Proposal is to maintain the current safe
operation for all users, and mitigate the impacts of the NNG and IC WTGs on Leuchars flying
and radar based ATS operations.
5.1 Overview
The CAA, in CAP 725 [Reference 1], lays down extensive regulatory requirements to be applied
to the design of the airspace arrangements. However, most of these requirements, such as IFP
containment, are relevant to the development of CAS, which is not the case with this TMZ
proposal as the proposed TMZ lies within Class G uncontrolled airspace. The significant
regulatory requirements applicable to this proposal are that the:
Dimensions of the proposed airspace should be the minimum practicable to meet
the safety and operational requirements; and
Configuration of the airspace should be as simple as practicable.
Thus, the primary matters for consideration in the development of the proposed TMZ are the
lateral and vertical dimensions, including alignment with any other, pre-existing, airspace
boundaries and the impact on:
Those aircraft wishing to use the airspace which are not and/or cannot be equipped
with a transponder; and
The operational impact on adjacent Air Traffic Service Units (ATSU) who may be
radar equipped, but not be SSR equipped.
The second point can be discounted immediately since there are no adjacent radar equipped
ATC units without SSR facilities. A potential drawback of establishing a TMZ is that non-
transponding aircraft may choose to take an alternative route in order to ‘bypass’ the TMZ,
resulting in a change in traffic patterns and ATC workload in this area. This would only
reasonably occur when aircraft have been unable to establish two-way radio communications
with Leuchars ATC, the TMZ Controlling Authority, who are available H24 as Leuchars could,
subject to traffic, allow a non-SSR equipped aircraft to transit the TMZ. A survey of the airspace
above the Development Areas was conducted over a weeklong period in March 2015 utilising
the Leuchars PSR during good weather conditions. During the survey, no non-transponding
aircraft were seen to transit the area of the proposed TMZ. Feedback from the ATC control staff
at Leuchars indicated that since the location of the Development Areas is over six NM offshore,
the incidence of non-transponding aircraft operating over the area is extremely rare. The
survey will be repeated in June 2015.
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5.2 Aim
The overall aim of the NNG and IC Airspace Change Proposal is to maintain airspace safety for
all users, and mitigate the impacts of the NNG and IC WTGs on Leuchars flying and radar based
ATS operations. It is envisaged that this will be achieved through the establishment of a TMZ
with a combination of RAG (Leuchars PSR blanking).
The secondary objective of the mitigation solution is to minimise any known airspace impacts
by allowing continuity of a full suite of ATSOCAS provision within the vicinity of the
Development Areas. Consequently, the proposed TMZ designs are intended to be sympathetic
to the existing airspace structure, traffic patterns and ATC operational norms in the area of the
proposed TMZ.
5.3 TMZ Boundary Requirements and Operation
5.3.1 TMZ Horizontal Buffer Zone
Removing the WTG clutter with Leuchars radar blanking (RAG) would have the consequent
removal of all PSR returns within the Development Areas. The developers will define the
precise layout of the WTG array. A decision on a final layout will occur post TMZ application. It
is therefore likely that the blanked area of the Leuchars PSR will reduce to cover the WTG array.
The objective of establishing the TMZ is not to prevent aircraft from operating near the WTGs,
merely to require that they operate a transponder when so doing. Notwithstanding this, there is
always potential for a non-transponder equipped aircraft to enter the TMZ inadvertently,
thereby becoming invisible to the radar controller. This would pose a potential threat to other
flights under the jurisdiction of the controller; a non-transponding aircraft entering the TMZ
would simply disappear from the controller’s display if the TMZ were to be restricted to the
limits of the WTG array or the control of entry to the TMZ by non-transponding aircraft is not
controlled. Once a non-transponding aircraft has entered the TMZ, assurance in providing
separation from other aircraft operating within it is lost.
In order to assure safe and expeditious ATS provision, an additional lateral buffer for ATS
purposes is necessary, particularly to mitigate the potential navigation error that might occur
whenever pilots of non-transponding aircraft fly close to the ‘blanked’ area. Whilst the chance
of non-transponding aircraft operating within the vicinity of the proposed TMZ is extremely
remote, this means that controllers would detect a non-transponding aircraft tracking towards
the lateral limits of the TMZ before it enters, and would be able to provide pertinent information
to aircraft operating within the airspace. Thus, it is concluded that an additional volume of
airspace should be added to the Development Areas to assure safe and expeditious ATS
provision at all times.
Figures 7 and 8 below illustrate the lateral extent of the proposed TMZ in green for Option A
and B.
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Figure 7 Option A: NNG and IC Proposed TMZ including 2 NM Buffer Zone (lined in green).
Contains Ordnance Survey data © Crown Copyright. All rights reserved. 2013 License number.
Figure 8 Option B: NNG and IC Proposed combined TMZ including 2 NM Buffer Zone (lined in green).
Contains Ordnance Survey data © Crown Copyright. All rights reserved. 2013 License number.
42
5.3.2 Vertical Extent of the TMZ
It is proposed that the TMZ should extend from sea level up to FL 100 above the Development
Areas, since transponder carriage within airspace above FL 100 is already mandated (with some
exceptions).
5.3.3 TMZ Co-ordinates
The co-ordinates for the concept designs of the TMZ (with a two NM internal buffer zone) and
its proximity to military and civilian aerodromes measured from the airfield reference points
are provided at Annex A5.
5.3.4 Hours of Operation of the TMZ
Under normal UK Integrated Aeronautical Information Package (IAIP) [Reference 10]
arrangements, the operating hours of a particular airspace segment established for ATS
purposes are linked to the operating hours of the associated ATS Unit. Hence, it is proposed that
Leuchars ATC are the TMZ Control Authority with the TMZ operating hours replicating the
Leuchars ATC operating hours which are 24 hours to provide for military diversion aerodrome
purposes and the provision of Lower Airspace Radar Service (LARS). The information would be
published within the UK IAIP and other applicable aviation documentation, noting the LARS
frequency and timings, as well as the boundary of the TMZ.
5.4 Impact of the TMZ on Military Operations
The majority of UK and European-based military aircraft carry and operate SSR transponders;
in most cases, these are compatible with Mode S systems. The only UK military types that are
not transponder equipped are gliders. It is considered that military gliders are highly unlikely
to operate as far offshore as the Development Areas and so would be unaffected by the TMZ
requirements. The nearest military gliding establishment is at Arbroath Airfield (RM Condor);
informal consultation with the operators of the airfield concluded in no objection to the
proposal, as they are unlikely to operate so far offshore in the location of the proposed TMZ.
5.5 Impact of the TMZ on Other ATSUs
The effect of the TMZ on other ATSUs depends entirely upon whether the rotating blades of the
WTGs are detectable to the radar within the ATSU area of responsibilities. In addition, it will
also depend to some extent as to whether aircraft under its ATS provision are transponder
equipped.
5.5.1 Dundee Airport
Dundee Airport lies on the shore of the Firth of Tay and is located 3 km from the centre of
Dundee. The airport does not operate a PSR, with Leuchars providing radar services to aircraft
if requested. There is a twice-daily flight to London Stansted Airport and terminal facilities are
available. Tayside Aviation Limited is a flight training and aircraft servicing company based at
the airport and is the largest aircraft-training organisation in Scotland. The airport is open
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seven days per week with the capability to continue flight operations into the hours of darkness.
Fuel and aircraft servicing is available together with limited hangar space and repair facilities
for visiting aircraft. In periods of bad weather, navigation facilities and an ILS is available to one
of the runways.
Dundee Airport does not possess primary radar facilities and none of its IFPs is located within
the vicinity of the Development Areas. The operators of the airport have confirmed during
informal consultation that there would be no objection to the proposal to introduce the TMZ, as
their operation would be unaffected.
5.5.2 Perth Airport
Perth Airport is a general aviation airport located 5.6 km northeast of Perth, Scotland. The
airport is used by business and private aircraft and for pilot training. Perth Airport has a CAA
Ordinary Licence (Number P823) that allows flights for the public transport of passengers or for
flying instruction as authorised by the licensee although there are no commercial scheduled
flights from the airport; the airport does not have a PSR. It is Scotland’s main airport for general
aviation and is the base of the Scottish Aero Club. The airport is also home to numerous flight
training organisations providing private and commercial fixed and rotary winged flight training,
as well as microlight and autogyro training.
Perth Airport has three runways and conducts VFR operations without radar support. There
are no IFPs associated with the airport and no expected impact to operations conducted at the
airport, created by the TMZ. The operators of the airport have confirmed during informal
consultation that there would be no objection to the proposal to the introduction of the TMZ, as
their operation would be unaffected.
5.5.3 Aberdeen Airport
Aberdeen Airport is an international airport located 9.3 km northwest of the City of Aberdeen;
NATS provides ATC facilities under contract. The airport also serves as the main heliport for the
Scottish offshore oil industry with Bristow Helicopters, CHC-Scotia and Bond Offshore
Helicopters operating from the airport. General aviation flight training takes place and the
Scottish Air Ambulance operates fixed wing aircraft from the airport.
IFPs for the airport, together with details of the offshore helicopter routes, are published within
the UK IAIP. The Development Areas are at considerable range from the airport and the
published IFPs. Furthermore, there are no oil and gas offshore platforms located within the
vicinity of the Development Areas and none of the published helicopter routes will be affected
by the construction and operation of NNG and IC. Informal consultation with NATS Aberdeen
and the three helicopter operators concluded that there would be no adverse operational effects
created by the introduction of the proposed TMZ.
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5.5.4 Edinburgh Airport
Edinburgh Airport, located in the City of Edinburgh was the busiest Scottish Airport in 2014.
NATS supply air traffic services under contract. The airport is operated H24 and has the ability
to accept both visual and instrument traffic. Edinburgh Airport uses their PSR to support their
provision of navigational services to aircraft operating to/from the airport and to aircraft
requesting a service within proximity to their established controlled airspace. The closest
development (NNG) is located approximately 39 NM to the northeast of the airport, outside of
Edinburgh CAS and therefore no impact will be created by either development to ATC
operations at Edinburgh Airport. NATS Edinburgh Airport have confirmed during informal
consultation that no impact to their operations is expected by the introduction of the proposed
TMZ.
5.5.5 NATS Scottish Area Control Centre (ACC)
The Scottish ACC provides an en-route ATS to aircraft over Scotland, Northern Ireland, Northern
England and the North Sea, operated by NATS. In the area of the proposed TMZ, civil controllers
control aircraft on airway P18 and provide an ATS to transit service to traffic operating above
FL 195. Military controllers who are located in the London ACC also provide an ATS to aircraft
outside of controlled airspace in the region of the proposed TMZ and to military aircraft
operating in the area using the same radars as their civil counterparts.
During both pre and post application phase for both NNG and IC, NATS were consulted on the
potential impact of the Development Areas on their operations. NATS examined both the NNG
and IC applications from a technical and a safeguarding aspect, and had no objection to the
proposed developments. Informal consultation on the proposed TMZ was requested with the
Scottish ACC; however, they declined a meeting to discuss the proposal. NATS radars will not
detect WTGs within either of the Development Areas and therefore the introduction of the TMZ
is unlikely to affect NATS ACC operations within the Development Areas.
5.5.6 Arbroath Aerodrome
Arbroath Aerodrome also known as RM Condor is home to No 662 Volunteer Gliding Squadron
who use conventional gliders for glider training, from familiarisation flights to solo validation, to
members of the Air Training Corps and the Combined Cadet Force. The operators of the
aerodrome have confirmed that operations at the aerodrome will be unaffected by the
introduction of the TMZ.
5.5.7 Fife Aerodrome
Fife Aerodrome is an unlicensed aerodrome located two NM west of Glenrothes, Fife, Scotland.
The airfield is used by Tayside Aviation to train pilots; an air ground communications service is
provided during airfield opening hours. Parachuting also takes place regularly at the
aerodrome, especially at the weekend. The aerodrome does not possess a PSR, there has been
no response to a request for informal consultation; however, operations at the aerodrome are
likely to be unaffected by the introduction of the TMZ.
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5.5.8 Kingsmuir (Sorbie) Aerodrome
Kingsmuir Aerodrome is unlicensed and possesses a grass runway of approximately 580 metres
in length. The aerodrome is a base to fixed wing, flex-wing and rotary general aviation aircraft.
Operations at the aerodrome are likely to be unaffected by the introduction of the TMZ. A
request for informal consultation was made to the aerodrome however, no reply was received.
5.5.9 East Fortune Aerodrome
East Fortune Aerodrome is home to the National Museum of Flight Scotland. The East of
Scotland Microlight Club has been operating from the aerodrome since 1990 and it offers air
experience flight and instruction. Operations at the aerodrome are likely to be unaffected by the
introduction of the TMZ. A request for informal consultation was made to the aerodrome
however, no reply was received.
5.5.10 Archerfield Airstrip
Archerfield Airstrip is a small private grass strip located on close to Archerfield Links Golf Club.
It is not known if any aircraft are located at the airstrip, however, during the summer of 2014 it
hosted general aviation aircraft positioning for the Scottish Air Show held at East Fortune.
Informal consultation with the aerodrome informed that operations at the airstrip are likely to
be unaffected by the introduction of the TMZ.
5.6 Impact of the TMZ on Light GA Operations
In theory, the implementation of a TMZ may require extra equipment to be purchased and
installed into any aircraft not currently equipped with a transponder. This TMZ is proposed
within an area that is not currently routinely utilised by light aircraft: additionally, the
likelihood of civilian traffic, operating without either transponder or radio, adjacent to the
Development Areas is likely to be extremely low. However, the possibility exists that civilian
aircraft may wish to operate within the area and therefore there is a requirement to mitigate for
the potential effects as mentioned previously.
All aircraft operating on Public Transport flights within UK airspace are required to be equipped
with, as a minimum, Mode S Elementary transponders. It can be assumed that the majority of
General Aviation (GA) aircraft over 5700 kg Maximum Total Weight Authorised (MTWA) are
likely to be transponder equipped on the basis that such aircraft types which can be used for
public transport operations are likely to operate from time to time within Classes A, C or D CAS.
Thus, the predominance of non-transponder equipped aircraft affected by the proposed TMZ is
likely to be aircraft of less than 5700 kg MTWA, which are not operated on Public Transport
flights.
Whilst not prohibited from operating over water, the majority of pilots of light aircraft prefer to
minimise their over-water flight time by using shorter over-water routes. Notwithstanding the
transponder mandate within a TMZ, provision exists within the TMZ Rules for conditional
access by non-transponder equipped aircraft through prior arrangement with the appropriate
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ATS Unit. Occasionally, locally based (Dundee, Fife, Perth aerodromes) light aircraft might
undertake offshore “sight-seeing” flights which may include the Development Areas.
It is recognised that the majority of locally based light aircraft are, or will be, transponder
equipped. Given the ability for conditional access to the TMZ airspace by non-transponder
equipped aircraft it is anticipated, and, indeed, has been confirmed by most through informal
consultation, that the impact of a TMZ on light GA operations, including glider, microlight and
balloon operations, will be minimal.
5.7 Impact of the TMZ on Offshore Helicopter Operations
As outlined in Section 5.6 above, likely aircraft to be affected by the proposed TMZ are those
with an MTWA of less than 5,700 kg, as above this weight the aircraft are likely to be used for
public transport operations and will therefore be transponder equipped.
Offshore helicopter types are categorised into the following MTWA groups:
Extra Heavy Twin >20,000 kg (e.g. Chinook);
Heavy Twin >5,700 kg (e.g. Bell 214ST, Super Puma, EC225, S61 and S92);
Medium Twin 2,730 to 5,700 kg (e.g. Dauphin, EC155, S75 and AW139); and
Light Twin <2,730 kg (e.g. Bo105).
5.7.1 Bristow Helicopters
Bristow Helicopters, operating from Aberdeen Airport, supports the transportation of oil and
gas industry personnel in the North Sea. The Company has been awarded the UK Search and
Rescue (SAR) contract and within Scotland and will operate from bases at Inverness, Sumburgh,
Stornoway and Prestwick.
Bristow Helicopters operate a fleet of Eurocopter EC155 and EC225, SNIAS/Aerospatiale
AS332L Super Puma, Bell 412 and Sikorsky S-61, S-76 and S-92. They will acquire the Augusta
Westland AW 189 for future use in the SAR role.
5.7.2 CHC Scotia Ltd. Helicopters
CHC Helicopters, operating from Aberdeen Airport, is one of several global providers of
helicopter transportation services to the offshore oil and gas industry. CHC operates the marine
Search and Rescue service for the Irish Coast Guard at Shannon, Waterford, Sligo and Dublin
Airports and provides commercial Search and Rescue helicopter services for the United
Kingdom Maritime and Coastguard Agency.
CHC Helicopters’ fleet consists in a Sikorsky S61, Sikorsky S76, Sikorsky S92, Eurocopter AS365,
Eurocopter AS332, EC155, EC225 and AW139.
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5.7.3 Bond Offshore Helicopters
Bond Offshore Helicopters, operating from Aberdeen Airport, specialise in providing offshore
helicopter transportation services to and from the North Sea oil and gas platforms. Bond
operations include offshore wind farm and lighthouse maintenance and aerial lifting.
Bond Offshore Helicopters’ fleet consists of a Eurocopter 225 and AS365 Dauphin, Eurocopter
AS332 Super Puma, Augusta Westland AW139 and Sikorsky S-92.
5.8 Helicopter Main Routes (HMR)
HMRs are routes where helicopters operate on a frequent basis between Aberdeen Airport and
the offshore oil and gas platforms. There are no oil and gas platforms within the area of the two
developments, therefore, the incidence of helicopter movements within the Development Area
are likely to be helicopters supporting the developments within the Operations and
Maintenance (O&M) phase and occasional transit helicopter flights. All three of the helicopter
companies have confirmed in informal consultation that there will be no expected impact on
their operations by the introduction of the proposed TMZ.
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6 Environmental and Economic Considerations of a TMZ
Overall, it is anticipated that the environmental impact of a TMZ encompassing the
Development Areas will be neutral within the three major categories of noise, fuel burn and
local air quality because of the airspace change.
6.1 Overview
This section explores how the proposed changes may have an overall effect on the environment
in terms of noise pollution, fuel burn and local air quality. It further details what studies , if any,
are required to analyse the environmental impact of the proposed changes.
The airspace within which the TMZ is proposed lies offshore in Class G airspace. The closest
proximity of the TMZ to the coastline is greater than six NM. Notwithstanding that the proposed
TMZ airspace is not CAS, and no aircraft operations are excluded from it, although unlikely, it is
possible, that some GA operators might elect to route on or closer to shore to avoid the
requirements of the TMZ rather than routing offshore, directly through the TMZ. As airspace
activity in Class G airspace is not routinely monitored, it is not possible to accurately gauge or
anticipate those flights that would elect to re-route simply because of the TMZ, even though a
TMZ itself does not inhibit flight operations.
A survey of the airspace above the Development Areas was completed over a weeklong period
in March 2015 utilising the Leuchars PSR, during good weather conditions. During the survey,
no non-transponding aircraft were seen to transit the area of the proposed TMZ; furthermore,
feedback from the ATC controlling staff at Leuchars indicated that due the location of the
Development Areas being over six NM offshore, the incidence of non-transponding aircraft
operating over the area is extremely rare and none were regularly seen. The amount of civilian
GA traffic that will operate in the vicinity of the Development Areas is expected to be minimal
with the large majority of transit GA expected to remain close (within two NM) to the coastlines.
This survey on airspace usage will be repeated in June 2015.
6.2 Impact of Noise
For both design options, it is expected that the noise impact immediately after implementation
is not likely to be significantly different from the pre-implementation situation. The proposed
TMZ lies greater than six NM from the coastline and any additional air activity due to the
location of the TMZ is unlikely.
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6.3 Anticipated Level of Fuel Burn/CO2 Emissions
It is recognised that aircraft contribute to CO2 emissions and this has an impact on climate
change. A responsible approach to airspace planning is to balance the competing demands and
ensure that the most direct routes possible are used with optimal aircraft performance, as this
will minimise fuel burn and emissions and therefore reduce the impact upon climate change.
This airspace change proposal ensures that the present efficient routing of aircraft will be
sustained.
Access to the TMZ will be available whenever and wherever practicably possible; little
displacement or re-routing is anticipated for either of the design options; any re-route (although
highly unlikely to be required) is likely to be insignificant. The TMZ proposal will produce a
qualitative assessment of any environmental impacts and is anticipated to ensure sustainability
of the efficient routing of aircraft.
6.4 Anticipated Effect on Local Air Quality
CAP 725 [Reference 1], Appendix B, Annex 8 identifies that local air quality at ground level
remains largely unaffected by aircraft emissions that take place above 3,000 ft agl because
dispersion reduces concentration levels for these emissions. It is understood that in the context
of local air quality, the overall objective under CAP 725 is to determine whether the proposed
airspace changes will exceed any statutory air quality standards, and if so, what contribution the
airport operations make towards such departures.
Given that the proposed TMZ lies well offshore, Air Quality Standards are not anticipated to be
breached. An atmospheric dispersion modelling assessment is unlikely to be required because
of the airspace change.
6.5 Conclusions
Overall, it is anticipated that the environmental impact of a TMZ will be neutral within the three
major categories of noise, fuel burn and local air quality because of the airspace change. It is not
anticipated that the TMZ will reduce the environmental impact of aviation in the subject
airspace; however, it is reasonable to expect that the environmental impact of aviation in the
subject airspace will not worsen as a consequence of the change. Both tranquillity and visual
intrusion is unlikely to be impacted and, in the worst case, the numbers of those negatively
affected are not likely to increase significantly upon implementation. The establishment of the
TMZ is a safety requirement to enable radar-based ATS to be sustained near the NNG and IC
Development Areas. Any economic and environmental benefit is derived mainly from enabling
the Wind Farms to proceed and the avoidance of protracted re-routing of military aircraft
operating to and from Leuchars.
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7 Next Stages
Once stakeholder consultation has been completed and any issues arising have been dealt
with accordingly, NNGOWL and ICOL will submit a formal Airspace Change Proposal to the
Safety and Airspace Regulation Group (SARG) of the CAA, detailing the case for the
proposed TMZ.
7.1 Overview
This section summarises the consultation process and outlines the next steps to be taken
following the consultation period with a view to Airspace Change Proposal submission to the
CAA.
7.2 Consultation Summary
This document has presented the mitigation option proposed by NNGOWL and ICOL, in order to
maintain safe operations and effectively mitigate the negative effects that the NNG and IC WTGs
will have on Leuchars flying and radar based ATS provision of ATS. It is envisaged that this will
be achieved through the establishment of a TMZ with associated RAG (PSR blanking over the
area of the WTGs). The secondary objective of the mitigation solution is to minimise any known
airspace impacts. Consequently, the proposed TMZ design is intended to be sympathetic to
existing airspace structure, traffic patterns and local ATC operational norms.
NNGOWL and ICOL are consulting widely on the proposed solution in order to identify any
unforeseen impacts. It is anticipated that overall environmental impacts of the proposed
airspace change will be neutral within the three major categories of noise, fuel burn and local air
quality. Both tranquillity and visual intrusion are also unlikely to be impacted. NNGOWL and
ICOL believe that any economic and environmental benefit will be derived mainly from enabling
the Wind Farms to proceed and the avoidance of protracted re-routing of military aircraft
operating on established IFPs to and from Leuchars.
7.3 Consultation Results
All consultee responses will be recorded and closely monitored as they are received. Individual
responses will not be acknowledged unless the consultee requests an acknowledgement.
However, if any clarifications are required, consultees will be contacted for further details in
order to provide an informed response. All objections to the proposal will be considered
carefully and a response will be provided to the consultee. On closure of the consultation
period, feedback will be provided to all consultees by means of a report that will highlight the
key themes that arise and how NNGOWL and ICOL will incorporate those concerns into their
plans. The Consultation Feedback Report will be published on the NNGOWL and ICOL websites
at:
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http://www.inchcapewind.com
http://www.neartnagaoithe.com
The records of consultation correspondence and the analysis of the results will be presented in
a Consultation Report, which will be presented to the CAA as part of the overall airspace change
submission.
7.4 What Happens Next?
Following the completion of the stakeholder consultation, modifications may be required in
light of responses. Once analysis of all responses has been completed, NNGOWL and ICOL will
submit a formal Airspace Change Proposal to SARG at the CAA detailing the case for the
proposed solution. It is a requirement of the consultation process that NNGOWL and ICOL will
provide the CAA with full details of the consultation (including copies of responses and
correspondence) together with all documentation necessary for the promulgation of the
proposed TMZ.
The CAA requires a period of 16 weeks in order to conduct its own internal analysis of the final
proposal and consultation results, before arriving at a Regulatory Decision. Should the CAA
accept the Airspace Change Proposal without the need for further design optimisation or
analysis, NNGOWL and ICOL suggest that the implementation of the TMZ should take place on a
single date to coincide with the earliest operational date of the NNG and IC Wind Farms. Clutter
will not be apparent on radar systems until the WTGs are operating.
NNGOWL and ICOL propose to detail the TMZ within the UK Mil AIP, in UK IAIP ENR GEN 1.5
(Aircraft Instruments, Equipment and Flight Documents) and ENR 6.1 (Helicopter Main Routes
and Northern North Sea Off-Shore Safety Area (OSA), and any other applicable military
documentation. Figure 9 below is an example of how the TMZ would be publicised. This would
serve the purpose of formally notifying the TMZ.
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Figure 9 NNG and IC Proposed TMZ (lined in green) ENR 6.1 proposed entry based on design Option B.
Reproduced from CAA digital map data © Crown copyright 2014. UK IAIP ENR.
53
8 References
Table 1 Table of References
Reference Name Origin
1 CAP 725 CAA Guidance on the Application of the Airspace Change
Process
Third Edition (corrected) April 2007
CAA
ISBN 978 0 11790 739 3
2 MOD HQ Air Command (HQ Air) Battlespace Management Safety
Management Manual (BM SMM), Edition 2.1 (AL3), 2 June 14
MOD
3 CAP 393 Air Navigation: The Order and the Regulations
Fourth Edition 21 January 2015
CAA
4 DAP Policy: Transponder Mandatory Zone (TMZs)
17 April 2009
CAA
5 MAA Manual of Military Air Traffic Management
First Published 17 November 2014
Last Updated 4 February 2015
MOD
6 Military Aeronautical Information Publication
AIRAC Cycle 04
No1 AIDU
7 CAP 493 Manual of Air Traffic Services (MATS) Part 1
Version 5.2 6 March 2014 Superseded 16 October 2014
CAA
ISBN 978 0 11792 780 3
8 Regulatory Article 3241
SSR Alone Operations February 2015
MAA
9 CAP 774 The UK Flight Information Services
Version 2.3 4 February 2015
CAA
54
10 UK Integrated Aeronautical Information Package
AIRAC 04/2015
NATS AIS
55
A1 Annex 1 NNG Wind Farm Line of Sight Assessment
A1.1 Overview
This Annex contains the results of the radar Line Of Sight (LOS) assessment for the NNG WTGs
in respect of the PSR located at Leuchars.
The analysis was carried out using representative points, (labelled 1-11) on the NNG
Development Area, as illustrated in Figure 10, and detailed in Table 2 below.
Figure 10 NNG Boundary Points around the Development Area considered for the LOS Assessment.
Contains Ordnance Survey Data © Crown Copyright and database right 2013.
Table 2 Summary of Development Area boundaries.
Boundary Point Latitude WGS84 Longitude WGS84 Blade Tip Height (m)
1 N56.254514o W2.164969o 197
2 N56.212024o W2.154251o 197
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Boundary Point Latitude WGS84 Longitude WGS84 Blade Tip Height (m)
3 N56.212526o W2.233308o 197
4 N56.212768o W2.271549o 197
5 N56.257986o W2.327131o 197
6 N56.263775o W2.334248o 197
7 N56.290508o W2.337206o 197
8 N56.329192o W2.297092o 197
9 N56.338526o W2.275308o 197
10 N56.336184o W2.248497o 197
A1.2 LOS Assessment Methodology
Over the distance between a PSR and a WTG, radar signal will attenuate (lose power) and be
refracted and diffracted (change direction). The likely radar performance characteristics for the
assessed radar station were predicted in order to model the radar signal. The intervening
terrain and signal path between the assessed radars and the boundary points of the
Development Areas of NNG have been modelled using ATDI ICS LT. For LOS analysis, the terrain
path has been assessed to determine whether the intervening terrain is likely to be significant
enough to prevent the WTGs / boundary points being detectable by radar. The direct LOS and
the 1st Fresnel zone, an elliptical zone around the direct LOS where the radio waves remain
strong, were assessed. Objects that infringe upon the Fresnel zone or the direct LOS will cause
the signal to diffract and attenuate. The effect of diffraction means that the direct transmitted
radio waves and those in the upper 1st Fresnel zone can still reach the WTG and be returned to
the radar receiver, hence why it is not always obvious that terrain shielding is sufficient.
A1.3 LOS Assessment Results
The LOS assessment has been completed based on a selection of five boundary locations spread
around the Development Area. The consented tip height 197 m above sea level (ASL) has been
used for the analysis. Osprey concludes that all of the NNG Development Area boundary points
are highly likely to be detected by the Leuchars radar: direct line of sight exists between the
radar and the WTG / boundary points. Due to the fact that the boundary points with WTGs of
197 m for the NNG Development Area share the same results, the image for Point 1 will only be
shown in this section to provide an example of Osprey’s findings.
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Figure 11 LOS Profile between the Leuchars PSR and Point 1 at NNG.
LOS diagrams have been produced illustrating the likely detectability of the NNG Offshore Wind
Farm by the assessed radar stations. Within the diagram above), the signal propagation is
modelled from the radar (far most left) to the WTG blade tip (far most right). The black line in
the diagram with area underneath filled in dark brown represents the terrain profile between
the radar and the boundary point. The red line in the diagram represents the direct LOS
between the two locations. The orange ellipse around the direct line of sight represents the 1st
Fresnel zone. The light blue and magenta lines are not relevant to this assessment.
Table 3 Summary of LOS results.
Radar Station Approx. Range to NNG Development Area
Boundary
Assessment Result
Leuchars (PSR) 34 km / 18.4 NM Yes (for all points)
A1.4 Conclusion
In conclusion, with a blade tip height of 197 m above sea level (ASL), the boundary points for
the NNG Development Area are highly likely to be detected by the PSR at Leuchars due to the
lack of intervening terrain that exists between the radar and the proposed development.
Although every care has been taken during the line of sight modelling and analysis process,
modelling limitations and assumptions obviously lead conclusions to be based on theoretical
results. The results are therefore indicative, and actual radar performance may differ from this
analysis.
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A2 Annex 2 IC Wind Farm Line of Sight Assessment
A2.1 Overview
This Annex contains the results of the radar Line Of Sight (LOS) assessment for the IC WTGs in
respect of the PSR located at Leuchars. The analysis was carried out on representative points
(labelled A to N) on the IC Development Area as illustrated in Figure 12 below and presented in
Table 4.
Figure 12 IC Boundary Points around the Development Area considered for the LOS Assessment.
Contains Ordnance Survey Data © Crown Copyright and database right 2013.
Table 4 Summary of Development Area Boundaries.
Boundary Point Easting/Northing Blade Tip Height (m)
Point A 397208/728451 215
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Boundary Point Easting/Northing Blade Tip Height (m)
Point B 392328/725577 215
Point C 385902/725670 215
Point D 382411/731833 215
Point E 382484/736818 215
Point F 384813/742889 215
Point G 389723/744763 215
Point H 390371/743575 215
Point I 389830/731691 215
Point J 397183/730129 215
Point K 386775/738980 215
Point L 385940/733755 215
Point M 387142/729476 215
Point N 392637/728294 215
A2.1 LOS Assessment Results
The LOS assessment has been completed based on all boundary locations around the
Development Area. The consented tip height 215 m above sea level (ASL) has been used for the
analysis. Osprey concludes that all of the IC Development Area boundary points with WTGs of
215 m are highly likely to be detected by the radar: direct line of sight exists between the radar
and the WTG / boundary points. Due to the fact that the boundary points for the IC
Development Area share the same results, the image for Point A will only be shown in this
section to provide an example of Osprey’s findings.
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Figure 13 LOS Profile between the Leuchars PSR and Point A at IC.
LOS diagrams have been produced illustrating the likely detectability of the IC WTGs by the
assessed radar station. Within the Figure above, the signal propagation is modelled from the
radar (far most left) to the WTG blade tip (far most right). The black line in the diagram with
area underneath filled in dark brown represents the terrain profile between the radar and the
boundary point. The red line in the diagram represents the direct LOS between the two
locations. The orange ellipse around the direct line of sight represents the 1st Fresnel zone. The
light blue and magenta lines are not relevant to this assessment.
Table 5 Summary of LOS Results.
Radar Station Approx. Range to IC Offshore
Development Area Boundary
Assessment Result
Leuchars (PSR) 37 km / 20.1 NM Yes (for all points)
A2.2 Conclusion
In conclusion, with a blade tip height of 215 m above sea level (ASL), the boundary points for IC
highly likely to be detected by the PSR at Leuchars Airfield due to the lack of intervening terrain
that exists between the radar and the Development Area.
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A3 Annex 3 Cross Section of Airspace above the Development Areas
Figure 11 below illustrates a cross section of the airspace above the NNG and IC Development
Areas, with the main providers of ATS noted at the right hand side. Airway P18 that straddles
the eastern edge of IC is included for completeness.
Figure 14 Cross Section of Airspace above the Development Areas (not to scale).
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A4 Annex 4 Leuchars Instrument Flight Procedures
A4.1 Overview
The following figures provide a visual indication of the location of the Leuchars IFPs and design
Options A and B within the Development Areas, both of which will effectively mitigate the
effects created by the operational WTGs.
A4.2 Leuchars Standard Instrument Departures (SID) – Runway 08 Figure 15 Leuchars SID Runway 08.
Option A Option B
© UK MOD Crown Copyright, 2014 Crown Copyright material reproduced with the permission of the Controller of HMSO.
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A4.3 Leuchars SID - Runway 26
Both Option A and B designs are located to the east of the published route outside of the area of
the figure, however, the SIDs heading east will take departing aircraft utilising the SID towards
the Development Areas.
Figure 16 Leuchars SID Runway 26.
© UK MOD Crown Copyright, 2014 Crown Copyright material reproduced with the permission of the Controller of HMSO.
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A4.4 Leuchars HI TAC to Precision Approach (PAR) – Runway 08
Figure 17 Leuchars HI TAC to PAR Runway 08.
Option A Option B
© UK MOD Crown Copyright, 2014 Crown Copyright material reproduced with the permission of the Controller of HMSO.
A4.5 Leuchars HI TAC – Runway 08 Figure 18 Leuchars HI TAC Runway 08.
Option A Option B
© UK MOD Crown Copyright, 2014 Crown Copyright material reproduced with the permission of the Controller of HMSO.
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A4.6 Leuchars TAC or RDR to ILS/DME - Runway 26
Figure 19 Leuchars TAC or RDR to ILS/DME Runway 26.
Option A Option B
© UK MOD Crown Copyright, 2014 Crown Copyright material reproduced with the permission of the Controller of HMSO.
A4.7 Leuchars HI TAC - Runway 26 Figure 20 Leuchars HI TAC Runway 26.
Option A Option B
© UK MOD Crown Copyright, 2014 Crown Copyright material reproduced with the permission of the Controller of HMSO.
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A5 Annex 5 Proposed TMZ Co-ordinates
The co-ordinates for the two options for concept design of the TMZ (including an internal two
NM buffer zone) are provided below.
Table 6 Option A TMZ Co-ordinates.
Point ID
NNG IC
Latitude Longitude Latitude Longitude
1 N56° 12’14.70” W2° 5’ 46.22” N56° 31’ 30.76” W2° 20 47.05”
2 N56° 11’ 58.96” W2° 5’ 55.48” N56° 32’ 0.71” W2° 20 36.52”
3 N56° 10’ 43.41” W2° 9’ 17.87” N56° 32’ 6.06” W2° 20 33.15”
4 N56° 10’ 45.21” W2°14’ 2.32” N56° 32’ 7.62” W2° 20 32.02”
5 N56° 10’ 46.08” W2°16’ 19.96” N56° 35’ 22.07” W2° 18 18.85”
6 N56° 11’ 38.24” W2° 19 15.05” N56° 36’ 31.44” W2° 16 13.94”
7 N56° 14’20.98” W2° 22 35.30” N56° 37’ 32.56” W2° 11 26.27”
8 N56° 14’ 41.85” W2°23’ 0.98” N56° 36’ 38.27” W2° 6’ 57.65”
9 N56° 15’ 42.17” W2° 23 38.28” N56° 35’ 59.90” W2° 6’ 19.58”
10 N56° 17’ 18.48” W2° 23’ 49.09” N56° 35’ 59.71” W2° 6’ 19.39”
11 N56° 17’ 44.53” W2° 23’ 46.82” N56° 35’ 56.70” W2° 6’ 16.54”
12 N56° 18’ 25.37” W2° 23 20.80” N56° 35’ 54.76” W2° 6’ 14.74”
13 N56° 20’ 44.69” W2° 20 56.52” N56° 28’ 42.09” W1° 59’ 37.19”
14 N56° 21’ 19.74” W2° 20 1.62” N56° 27’ 49.67” W1° 59’ 13.83”
15 N56° 21’ 53.36” W2° 18 43.18” N56° 27’ 4.98” W1° 59’ 12.66”
16 N56° 22’ 16.98” W2° 15 57.50” N56° 26’ 24.53” W1° 59’ 18.40”
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Point ID
NNG IC
Latitude Longitude Latitude Longitude
17 N56° 22’ 8.54” W2° 14 20.90” N56° 25’ 10.45” W2° 0’ 58.71”
18 N56° 21’ 9.30” W2° 11 46.97” N56° 23’ 37.37” W2° 5’ 43.21”
19 N56° 16’ 15.16” W2° 6’ 46.54” N56° 23’ 20.60” W2° 7’ 36.22”
20 N56° 15’ 32.80” W2° 6’ 20.80” N56° 23’ 23.08” W2° 13 50.92”
21 N56° 12’ 59.81” W2° 5’ 42.45” N56° 24’ 23.60” W2° 16 56.26”
22 N56° 12’ 21.33” W2° 5’ 44.06” N56° 27’ 42.40” W2° 20 21.65”
23 N56° 12’ 14.70” W2° 5’ 46.22” N56° 28’ 42.90” W2° 20’ 50.09”
24 N56° 31’ 24.14” W2° 20’ 47.31”
25 N56° 31’ 30.76” W2° 20’ 47.05”
Table 7 Option B TMZ Co-ordinates.
Point ID Latitude Longitude
1 N56° 10’ 43.410” W2° 9’ 17.874”
2 N56° 10’ 45.216” W2° 14’ 2.323”
3 N56° 10’ 46.089” W2° 16’ 19.964”
4 N56° 11’ 38.247” W2° 19’ 15.051”
5 N56° 14’ 20.989” W2° 22’ 35.306”
6 N56° 14’ 41.859” W2° 23’ 0.987”
7 N56° 15’ 42.175” W2° 23’ 38.288”
8 N56°17’18.487” W2° 23’ 49.097”
9 N56° 17’ 44.539” W2° 23’ 46.828”
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10 N56° 31’ 30.766” W2° 20’ 47.054”
11 N56° 32’ 0.710” W2° 20’ 36.524”
12 N56° 32’ 6.063” W2° 20’ 33.155”
13 N56° 32’ 7.620” W2° 20’ 32.024”
14 N56° 35’ 22.077” W2° 18’ 18.858”
15 N56° 36’ 31.442” W2° 16’ 13.943”
16 N56° 37’ 32.565” W2° 11’ 26.275”
17 N56° 36’ 38.278” W2° 6’ 57.655”
18 N56° 35’ 59.903” W2° 6’ 19.580”
19 N56° 35’ 59.718” W2° 6’ 19.391”
20 N56° 35’ 56.701” W2° 6’ 16.547”
21 N56° 35’ 54.763” W2° 6’ 14.744”
22 N56° 28’ 42.096” W1° 59’ 37.191”
23 N56° 27’ 49.678” W1° 59’ 13.838”
24 N56° 27’ 4.984” W1° 59’ 12.660”
25 N56° 26’ 24.530” W1° 59’ 18.402”
26 N56° 12’ 14.704” W2° 5’ 46.226”
27 N56° 11’ 58.966” W2° 5’ 55.480”
The proximity of TMZ to military and civilian aerodromes (measured from the aerodrome
airfield reference point where provided) are provided below.
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Table 8 TMZ Proximity to Military and Civilian Aerodromes.
Aerodrome Proximity of edge of TMZ (NNG)
(NM)
Proximity of edge of TMZ (IC)
(NM)
Leuchars 18.1 20
Dundee Airport 24.9 24.6
Perth Aerodrome 36.5 36.2
Aberdeen Airport 52 36.5
Edinburgh Airport 39.5 47.6
Arbroath Aerodrome (RM Condor) 18.4 11.4
Fife 28.9 35
Kingsmuir (Sorbie) Aerodrome 13.9 19.7
East Fortune Aerodrome 20.7 30.4
Archerfield Aerodrome 20.4 29.7
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A6 Annex 6 Stakeholder / Consultee List
A6.1 Aviation Consultees
National Organisations (NATMAC)
Consultation Acronym
Airport Operators Association AOA
Aircraft Owners and Pilots Association AOPA UK
Association of Remotely Piloted Aircraft Systems ARPAS
Aviation Division Navy Command Headquarters NCHQ
Aviation Environment Federation AEF
BAE Systems BAES
British Air Transport Association BATA
British Airline Pilots’ Association BALPA
British Airways BA
British Balloon and Airship Club BBAC
British Business and General Aviation Association BBGA
British Gliding Association BGA
British Hang Gliding and Paragliding Association BHPA
British Helicopter Association BHA
British Microlight Aircraft Association BMAA
British Model Flying Association BMFA
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British Parachute Association BPA
Civil Aviation Authority CAA SARG
Defence Airspace and Air Traffic Management (incl. the Military User Advisory
Consultative Team) DAATM (MUACT)
Euro UAV Systems Centre Ltd UAVS
European Low Fares Airline Association ELFAA
General Aviation Safety Council GASCo
Guild of Air Pilots and Air Navigators GAPAN
Guild of Air Traffic Control Officers GATCO
Heathrow Airport
Heavy Airlines
Helicopter Club of Great Britain HCGB
Light Aircraft Association LAA
Light Airlines
Low Fares Airlines
Military Aviation Authority MAA
Ministry of Defence MOD
National Air Traffic Services NATS
NATS En-route plc NSL
PPL/IR Europe PPL/IR
Safety and Airspace Regulation Group SARG
UK Airprox Board UKAB
UK Flight Safety Committee UKFSC
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3 AF-UK/A3
Local Aerodromes
Consultee Also known As Point of Contact
Leuchars EGQL SATCO
Dundee Airport EGPN SATCO
Perth Aerodrome EGPT SATCO
Aberdeen Airport EGPD SATCO
Edinburgh Airport EGPH SATCO
Arbroath Aerodrome RM Condor OC 662 VGS
Fife Aerodrome EGPJ SATCO
Kingsmuir Aerodrome Sorbie Mr D Smith
East Fortune Aerodrome Mr G Douglas
Archerfield Airstrip Duchess of Hamilton
Aviation Organisations
Consultee Point of Contact
Bristow Helicopters Limited Aberdeen Bristow Helicopters Limited Aberdeen
Dunlin Road
Aberdeen
AB21 0PB
+44 (0) 1227 723151
CHC Scotia Helicopters Aberdeen communications@chc.ca
Head Office (Aberdeen) +44 (0) 1224 846000
Bond Offshore Helicopters Aberdeen adoyle@bondoffshorehelicopters.com
British Association of Balloon Operators (BABO) comms@babo.org.uk
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Eastern Airways customerrelations@easternairways.com
Fisheries Protection Agency
Helicopter Safety Steering Group hssg@stepchangeinsafety.net
Loganair neilheron@loganair.co.uk
NATS Limited Aberdeen john.mayhew@nats.co.uk
NHV UK (North Sea Helicopters) colinhancy@nhv.be
The General Aviation Alliance facilitator@gaalliance.org.uk
A6.2 Non-Aviation Consultees
Consultee Point of Contact
Friends of the Earth Friends of the Earth Edinburgh,
Edinburgh Peace and Justice Resource Centre
St. John’s Centre, Princess Street, Edinburgh EH2 4BJ
Scottish National Heritage Scottish National heritage Aberdeen
Inverdee House
Baxter Street, Torry, Aberdeen AB11 9QA
enquiries@snh.gov.uk
Northern Lighthouse Board Northern Lighthouse Board,
84 George Street, Edinburgh, EH2 3DA
Maritime and Coastguard Agency HM Coastguard Operations
Bay 2/06 Spring Place, 105 Commercial Road
Southampton, Hampshire, SO15 1EG
A6.3 Information Organisations: Civil Aviation Authority
Consultee Also known As
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Safety and Airspace Regulation Group SARG
Safety and Airspace Regulation Group Head of
Aerodrome & Air Traffic Standards Division SARG Hd AATSD
Safety and Airspace Regulation Group Flight Ops
Division SARG Flight Ops Division
Safety and Airspace Regulation Head of Airspace
Regulation SARG Hd AR